1. Introduction

The purpose of this privacy policy ("Policy") is to inform you about how and why Fair-eZone collects and processes your personal data when you use:

• Our websites lekka.io and www.fair-ezone.com (the "Site"),
• The Lekka mobile application available on Android and iOS (the "Mobile Application"),
• Any services accessible via the Site or the Mobile Application (the "Lekka Services").

 

This Policy is also intended to inform you of your rights regarding your personal data. It is therefore important that you read it, as well as any other specific information that we may provide to you from time to time, when we collect or process personal data about you.

2. The data controller

 Fair-eZone SAS, a French simplified joint stock company registered in Tours under no. 800 845 323, with its registered office at 27 rue Mansart, 37300 Joué-lès-Tours, France, is the data controller for the processing activities for which it determines the purposes and means, in particular in connection with the Site, the Mobile Application and the Lekka Services that it provides.

 

For certain onboarding and payment-service processing carried out through the Mobile Application, Fair-eZone acts as a data processor on behalf of Paynetics AD. Paynetics AD remains the data controller for the payment services that it provides. Further information about these processing activities is available in Paynetics AD’s privacy policy.

 

In this Policy, the terms "we", "us", "our" refer to the company Fair-eZone.

3. The personal data we collect

When providing its services, Fair-eZone may collect and process the following categories of personal data about you:

 

When you subscribe to our Lekka Services:

• Identification and verification data, such as your title, name, date and place of birth, nationality, identity document, photographs used for liveness and face-matching checks, the results of those checks, residential address, address-verification data and results, and professional information. Where a qualified electronic signature is used, this may also include the signed document, data contained in the qualified certificate and records evidencing the electronic signature process.
• Contact information, such as your email and postal addresses and mobile phone
• Financial and banking data, such as monthly income level, expected top-up level, expected expenditure

 

Some identity and residential-address verification data may be obtained from reliable and independent sources rather than directly from you. These may include databases made available by verification service providers and, where applicable, publicly available sources. These sources may provide data or a verification result indicating whether the information you provided matches their records. Where the available information is insufficient, we may ask you to provide supporting documents or additional information.

 

When you use our Lekka Services to complete a transaction:

• Transactional data, such as the amount, currency, card number, bank account number, account balance, merchant or supplier details, beneficiary name and bank details, and the result of any beneficiary verification performed before a bank transfer.
• Profile data, such as your preferences when using the Lekka Services and your direct marketing
• Lekka Services usage data, for troubleshooting incidents as part of customer

 

When you browse the Site or use the Mobile Application:

• Technical and security data, such as your device model, browser, IP address, an identifier assigned to the app instance or device, information about your use of the Mobile Application or the Site, and security diagnostics relating to the integrity and runtime environment of the Mobile Application and the device, including indicators such as rooting or jailbreaking, use of an emulator or hooking framework, or an active VPN.
• If you expressly authorize us to do so, your geolocation data, your mobile phone contacts, your mobile phone status data (mobile ID, language...) and, during the identification document collection phase, the images from your phone's camera, in order to scan your identification documents. You can withdraw your consent at any time by disabling the authorization given for the Mobile application in your device

 

This data is collected and processed for the purposes described below, depending on whether you use the Site, the Mobile Application or our Lekka Services.

 

Where we need to collect personal data about you (under a legal obligation or a contract that we have with you, or that we are intending on entering into with you) and you fail to provide such personal data when requested, we may not be able to provide you with the services you require. The mandatory nature is indicated to you at the time of collection.

4. Why we process your personal data

The table below shows you the reasons why your personal data is collected and the legal basis on which Fair-eZone processes your data in accordance with applicable laws and regulations.

 

Activity / Purpose of the processing	Legal basis	Legitimate interest (where applicable)
To provide the Lekka Services, including identity and address verification and, where applicable, support for a qualified electronic signature process	Our contract Our legitimate interest  Our legal obligations	Our commercial interest in providing you with quality service
To fight against fraud	Our contract Our legal obligations
To help market Lekka Services and those of our partners that interest you	Our legitimate interest Your consent	Our commercial interest in facilitating the marketing of Lekka Services and promoting those of our partners   Our business interest in improving our knowledge of the types of customers using our Lekka Services
To keep the Lekka Services operational and develop new services	Our contract Our legitimate interest Our legal obligations	Our commercial interest in providing you with effective service and support   Our commercial interest in providing you with new services

 

Where Fair-eZone acts as a processor for Paynetics AD, the purposes and legal bases of the processing are determined by Paynetics AD and are described in Paynetics AD’s privacy policy.

 

Please note that we may process your personal data on more than one lawful ground, depending on the specific purpose for which we use your personal data. For more details on this subject, do not hesitate to contact us at legal@fair-ezone.com

 

Fair-eZone does not take decisions based solely on automated processing that would produce legal effects concerning you or similarly significantly affect you.

5. Our use of "cookies”

When using our Websites or Mobile Application, information relating to the navigation of the device (computer, tablet, smartphone, etc.) may be stored in "cookie" files on the device, subject to the choices made regarding cookies which may be modified at any time.

 

3 types of cookies are used by Fair-eZone:

 

• Internal cookies required by the Site to operate

These cookies allow the Site to function optimally. They include, for example, cookies that allow you to connect to secure areas of our Site.

 

• Cookies for audience measurement

In order to adapt our Lekka Services to the requests of visitors of the Site, we measure the number of visits, the number of pages viewed as well as visitor activity and frequency of return. We use Google Analytics cookies. Google Analytics collects data about your traffic via Google advertising cookies and identifiers, in addition to data collected through a standard Google Analytics implementation. It reports on Site trends without identifying individual visitors. You can disable Google Analytics without affecting the way you visit the Site. For more information about Google Analytics, click here.

 

• Third-party cookies to improve Site interactivity

The Site relies on certain services offered by third party websites. These include videos posted on the Site (YouTube). These features use third-party cookies placed directly by these services. When you first visit the Site, a banner informs you of the presence of these cookies.

 

You block cookies by activating your browser setting which allows you to refuse the installation of all or part of the cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or part of our Site.

6. The recipients of your personal data

We do not rent or sell personal data and we do not disclose personal data to third parties for their own marketing purposes.

 

We share certain personal data with partners that provide specialised services. Depending on the processing concerned, these partners may act as processors on our or Paynetics AD’s instructions, or as separate data controllers for processing purposes that they determine themselves. These partners include:

• Paynetics AD, the issuer of the Lekka Card and the provider of the payment services accessible through the Mobile Application, including the verification of beneficiary details before SEPA transfers. Paynetics AD’s privacy policy is available here.
• Sum & Substance Limited (“Sumsub”), which provides identity and residential-address verification services and may support qualified electronic signature processes. Sumsub’s privacy notice is available here.
• Where a qualified electronic signature is used, the qualified trust service provider responsible for issuing the qualified certificate and enabling the signature. The identity of that provider and its privacy information will be made available during the signature process.

Personal data may also be transmitted to service providers acting on behalf of Fair-eZone or Paynetics AD, including identity and address-verification providers, anti-fraud providers and IT service providers. They may access personal data only to the extent necessary to provide their services and are subject to appropriate confidentiality and data-protection obligations.

 

We may also disclose your personal data (i) if we are required to do so by law (ii) to enforce our rights and protect the security of our services and (iii) in connection with mergers or acquisitions of companies.

7. International transfers and the security of your personal data

Your personal data may be processed within the EEA and, where necessary, in countries outside the EEA. Any transfer outside the EEA is carried out in accordance with applicable data protection laws, including, where applicable, on the basis of an adequacy decision or subject to appropriate safeguards such as the European Commission’s standard contractual clauses. Further information about the applicable transfer mechanisms and safeguards may be obtained by contacting us..

8. How long your personal data will be kept

Your personal data is kept by Fair-eZone for the time necessary to achieve the purposes for which it was collected.

 

To determine the appropriate retention period for your personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk resulting from the unauthorised use or disclosure of personal data, the purposes for which we process your personal data and our legal obligations.

9. Deleting your account

If you wish to terminate your relationship with Fair-eZone and delete your account, you may send a request by e-mail to the following address: support@lekka.io. Once the request has been received, we will confirm its receipt and provide you with the procedure to follow to close your account.

 

Closing your account does not automatically result in the deletion of all associated personal data. Any request to erase personal data will be handled in accordance with the right to erasure set out in Section 11.

10. Your privacy responsibilities

To help protect your privacy, be sure:

• Not to share your user ID or password with anyone else;
• To take customary precautions to guard against “malware” (viruses, Trojan horses, bots, etc.), for example by installing and updating suitable anti-virus software;
• To inform us, as soon as practicably possible, should any of the above take place.

11. Your rights

Depending on your personal situation, you have the rights listed below under data protection laws and regulations. We will honour your requests as required by applicable law, but keep in mind that these rights are not absolute: they do not always apply and may be subject to exceptions.

 

Right of access: You have the right to access the personal data we hold about you. This gives you the right to receive a copy of your personal data and certain information relating to the processing of your personal data.

 

Right to rectification: You have the right to ask us to correct your personal data if it is inaccurate or obsolete. If you have created a user account, you can correct some of your information by visiting your account.

 

Right to erasure: In certain circumstances, you have the right to request the deletion of your personal data. This right does not apply where processing remains necessary, including to comply with a legal obligation or to establish, exercise or defend legal claims. Certain personal data must be retained for 5 years from the end of the business relationship or from the relevant transaction, as applicable.

 

Right to object: where we are relying on a legitimate interest, you may object to the processing when your situation justifies it. In some cases, we may not grant your request if we demonstrate that the legitimate interest we are pursuing prevails. You also have the right to object to the processing of your personal data for direct marketing purposes at any time and without justification.

 

Right to restriction: You may request that we restrict the processing of your personal data in certain circumstances, for example while we verify its accuracy or assess an objection you have raised, or where you need the data for the establishment, exercise or defence of legal claims.

 

Right to data portability: We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used and machine-readable format. Please note that this right only applies to your personal data that we process automatically, (i) with your consent or (ii) in the context of the performance of a contract with you.

 

Use of your data after death: You can send us specific instructions regarding the retention, erasure and disclosure of your data after your death.

 

In addition, if the processing of your personal data is based on your consent, you also have the right to withdraw your consent at any time.

 

You will not have to pay a fee to access your personal data or to exercise any of the other rights referred to above. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to respond to your request in these circumstances.

 

We may ask you for specific information to help us confirm your identity and respond to your request. We try to respond to all legitimate requests within one month.

12. Information collected from minors

You must be at least 18 years old to use Lekka App services. Fair-eZone does not knowingly collect information from minors under 18.

13. Other information we may use

Fair-eZone offers the ability to make peer-to-peer payments in the app to other Lekka members. To use this function, we will require access to your phone contacts database. Before we access your phone contact database your permission will be requested. Fair-eZone does not store your phone contact database on our servers.

14. Contact us for more information

If you have any questions about how we use your personal data or if you wish to exercise any of the above rights, you can contact us by email or registered mail:

 

• legal@fair-ezone.com
• Fair-eZone (Privacy), 27 rue Mansart 37300 Joué-lès-Tours,

 

You may also file a complaint with the Commission nationale de l'informatique et des libertés (CNIL). We would, however, appreciate the opportunity to address your concerns before you approach the CNIL, so please contact us in the first instance.

15. Policy updates

We may amend this Policy from time to time. We ensure that the most recent version is published on the Site. When significant changes are made to the Policy, we will notify you by posting a notice online and/or sending you an email.

 

The Policy was last updated in September 2026.