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Lobster Privacy Policy

Last revised 27/11/2023


TLM SOLUTIONS and its affiliates (hereinafter referred to as "TLM SOLUTIONS", the "Company", "we", "us" or "our") are committed to protecting and respecting your privacy (hereinafter referred to as "Users", "you" or "your").

This privacy policy (hereinafter referred to as "Privacy Policy") together with our legal notice, disclaimers, documentation, general terms of use of the website and general terms and conditions (Lobster Terms & Conditions) explain how TLM SOLUTIONS operates and how it may - from time to time only - use your personal information (hereinafter referred to as "Personal Information" or "Personal Data") when Users access the website: www.lobster-protocol.com (hereinafter referred to as the "Site").

For more information about the Company, the User is invited to consult the legal notice: www.lobster-protocol.com/legal-notice

TLM SOLUTIONS has developed the Site and the Application (as defined in the Lobster Terms & Conditions) which consist in deploying a secured technical infrastructure, accessible via the Site, allowing Users to deposit digital assets into decentralized smart contracts, acting as vaults, managed by autonomous algorithms to generate financial returns.

In this context, this Privacy Policy describes why and how we may collect and use Personal Information and provides information about individuals’ rights in relation to Personal Information.


The purpose of this Privacy Policy is to set out in an accountable and transparent way the collection and use of information by TLM SOLUTIONS.

In order to comply with General Data Protection Regulation (GDPR) and applicable regulations, TLM SOLUTIONS may gather personal information from Users to facilitate the implementation its actions.


In order to benefit from the services available on the Application, each User must connect her/his User’s Wallet (as defined in the Lobster Terms & Conditions) to the Application. A User’s Wallet means the non-custodial Wallet, i.e., whose cryptographic private key is owned only by the User, e.g., Metamask (https://metamask.io/).


Personal Information is information which identifies you personally or by which your identity can reasonably be ascertained.
The Personal Information which may be processed is listed below.

What personal data may TLM SOLUTIONS collect and process?

-  Content, within any messages you send to us via our contact address: contact@lobster-protocol.com , such as feedback, questions, job applications, etc. Such messages may include:
• first and last name,
• email address,
• telephone number,
• nationality,
• personal address,
• professional experience,
• CV or biography.

Why does TLM SOLUTIONS process my personal data?

Communicating with you. We use your personal information to communicate with you regarding TLM SOLUTIONS.

Legal basis for our use of personal data

Fulfillment of a contract. When we provide products or services to you or communicate with you about them.

Legal obligation to comply with our legal obligations under applicable laws and regulations.

Legitimate interest and the interests of our Users when, for example, we detect and prevent fraud and abuse to protect the safety of our Users, ourselves or others.

Your consent when we ask for your consent to process your Personal Data for a specific purpose that we communicate to you. When you consent to TLM SOLUTIONS processing your Personal Data for a specific purpose, you may withdraw your consent at any time and we will stop processing your Personal Data for that purpose. Withdrawal of consent does not affect the lawfulness of the processing based on the consent prior to its withdrawal.|


TLM SOLUTIONS is committed to protecting your privacy. Internally, only a specified number of employees within our business have access to your Personal Information.

TLM SOLUTIONS’s systems and data are constantly under review to ensure that you are getting the best access.

TLM SOLUTIONS reserves the right to retain and share certain Personal Information in order to meet our regulatory and statutory requirements. In addition, TLM SOLUTIONS reserves the right to retain and share certain Personal Information with our corporate partners, and third parties acting on behalf of TLM SOLUTIONS.

Personal Information and other related data may be exported outside of the jurisdiction in which you reside. Your Personal Information may be processed and stored in a foreign country or countries. Under those circumstances, the governments, courts, law enforcement or regulatory agencies of that country or those countries may be able to obtain access to your Personal Information through foreign laws. You need to be aware that the privacy standards of those countries may be lower than those of the jurisdiction in which you reside.


You have the right to access the Personal Information we hold about you, and to require the correction, updating and blocking of inaccurate and/or incorrect data by sending an email to us. We will aim respond to your request within 14 days. You may also request the deletion or destruction of your Personal Information, your account details, etc.

TLM SOLUTIONS will act on your request only when it is not inconsistent with its legal and regulatory obligations and compliance procedures. Upon your written request, we will inform you of the use and general disclosure of your Personal Information.


You benefit, under the terms and conditions and within the limits defined by the legal and regulatory provisions on the protection of Personal Information, the following rights with regard to your Data:

Right of access
: you can obtain confirmation whether or not Personal Information concerning you is processed by the Company and, when they are, access to said Personal Information, as well as certain information relating to the processing of your Personal Information and the characteristics of such processing;

Right of rectification: you can request the correction of your Personal Information that you consider incomplete or inaccurate;

Right to erasure

Right to limitation of processing
: you can request limitation of processing of your Personal Information, allowing you to request in certain cases the marking of your Personal Information in order to limit future processing;

Right to the portability of your Personal Information: you have the right in certain cases and under certain conditions to request to receive the Personal Information concerning you that you have provided to us or, when technically possible, to they are transferred to a third party, in a machine-readable form (it being specified that this right to data portability only applies to processing based on the consent of the Persons concerned or on the execution of contractual relations, and this provided that the Data processing is carried out using automated processes);

Right to withdraw your consent: you can withdraw your consent if the processing is carried out on the basis of your consent, without the withdrawal of such consent prejudicing the lawfulness of the processing based on the consent made before the withdrawal of it;

Right to define guidelines for the retention, erasure or communication of your Personal Information after your death: in this regard, in the event of death which would be brought to our attention, please be aware that your Personal Information will in principle be deleted (unless it is necessary to keep it for a specified period for reasons relating to our legal and regulatory obligations), after having been communicated to a third party possibly designated by you.

Important notice: the exercise of these rights is nevertheless limited, with regard to Personal Data that may be necessary for the operation of a blockchain (i.e.in particular to the Data retained / stored within the blockchains used for the management, monitoring and processing of digital asset transactions). Indeed, this Data required for the operation of blockchains cannot be modified or erased during the lifetime of the blockchain in question. In addition, the retention / storage of said Data in said blockchains is not the responsibility of the Company, which does not manage nor control said blockchains, and therefore has no power to determine or control the processing of Personal Data which may be implemented in connection with said blockchains, nor to pass on the exercise by data subjects of their rights to said blockchains.

Regarding the processing of your Personal Information implemented by the Company, these rights are exercised:

by email to the following email address: contact@lobster-protocol.com,
by post to the address next: 6, rue des Bateliers, 92110 Clichy (France)

In any event, in the event of reasonable doubt as to the identity of the person submitting such a request to exercise their rights, the Company may always request that it be provided with additional information necessary to confirm the identity of the Person concerned and request for this purpose, when the situation so requires, a photocopy of an identity document bearing the signature of the holder.



With regard to cookies, the Company uses services provided by Google and other third parties that use tracking technology such as cookies, deviceID, and localStorage, to collect information about your use of the services and our interactions with you. You can opt out of having your online activity and device data collected through these third-party services, including by:

- Blocking cookies in your browser by following the instructions in your browser settings. For more information about cookies, including how to see the cookies on your device, manage them, and delete them, visit www.allaboutcookies.org.

- Blocking or limiting the use of your advertising ID on your mobile device through the device settings.

-Using privacy plug-ins or browsers. Certain browsers and browser extensions can be configured to block third-party cookies and trackers.

- Using the platform opt-out provided by Google at https://adssettings.google.com.

- You can learn more about how Google uses your information by reviewing Google’s privacy policy at https://policies.google.com/privacy.

- Using advertising industry opt-out tools on each device or browser where you use the Services, available at http://optout.aboutads.info and http://optout.networkadvertising.org.


A cookie is a small file for storing and retrieving information, generally made up of alphanumeric characters (cf. letters and numbers), deposited by a web server on the computer or electronic terminal of the User of the site to send state information to said browser and likewise obtain such information back from the browser. The status information can be for example a session identifier, a language, an expiration date, a response domain, etc.

Cookies usually make it possible to obtain certain information on the browsing habits of the User, his computer or his terminal, in particular in order to improve the content and the service offered by the site in question, to know the traffic of said site and to provide Internet Users with personalized services.

The notion of cookies covers all types of tracers or other similar technologies, for example:

- HTTP Cookies;
- but also the use of other techniques:“local shared objects” sometimes called “Flash Cookies”;
- “local storage” implemented within HTML 5;
- identifications by calculating the fingerprint of the terminal (“device fingerprinting”);
- identifiers generated by operating systems (whether advertising or not: IDFA, IDFV, Android ID, etc.);
- hardware identifiers (MAC address, serial number or any other identifier of a device);

In any case, cookies can be:

- session cookies, which disappear as soon as the User leaves the browser or the Site;
- where permanent cookies that remain until the expiration of their lifespan or validity, or until the User deletes them by means of the functionalities of his browser for example or through the cookie management module set available on our Site.


"Functional" cookies not subject to User consent

Functional Cookies, ie those whose sole purpose is to allow or facilitate electronic communication on, from or to a site or which are strictly necessary for the provision of a communication online at the express request of the User of a site, are exempt from the need for the publisher of a site to request the User's consent for their installation.

The Company may thus use such functioning cookies, in particular technical cookies essential for navigation on the Site and cookies strictly necessary for the provision of certain services explicitly requested by the User, without requesting prior consent from you. If the User deactivates these “operating” cookies for example by means of the functionalities offered by his browser, he may not be able to access the Site, and / or not correctly receive the content and information available on the Site and / or not being able to benefit from all the features of the Site.

Other cookies, subject in principle to the consent of the User

The use of other cookies as referred to below is subject in principle to the prior consent of the User, the latter being free to either accept them by expressly consenting to their installation and reading in his browser (it being specified that the latter will then have the possibility to withdraw his consent at any time), or to refuse them.


We take reasonable steps to protect your Personal Information from misuse, loss, unauthorized access, modification or disclosure, including implementing appropriate security measures. The security measures in place will, from time to time, be reviewed in line with legal and technical developments. However, we give no guarantee that such misuse, loss, unauthorized access, modification or disclosure will not occur. There are protective measures that you should take which as well include but are not limited to changing password regularly, not sharing your Personal Information with other unless you clearly understand the purpose of their request and you know with whom you are dealing.


We will hold your Personal Information only for as long as it is necessary for us to do so, having regard to the purposes described in this Privacy Policy and our own legal and regulatory requirements. In general, Personal Information relating to you shall be deleted after a period of five (5) years after your first email (or equivalent) to TLM SOLUTIONS.


There may be links from our Site to other sites and resources provided by third parties. This Privacy Policy applies only to our Site. Accessing those third-party sites or sources requires you to leave our Site. We do not control those third-party sites or any of the content contained therein and you agree that we are in no circumstances responsible or liable for any of those third party sites, including, without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to or arising from those sites. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each site that you visit.


Our policies, content, information, promotions, disclosures, disclaimers and features may be revised, modified, updated, and/or supplemented at any time and without prior notice at the sole and absolute discretion of the Company. If we change this Privacy Policy, we will take steps to notify all Users by a notice on our Site and will post the amended Privacy Policy on the Site.


If you consider that we have not responded adequately to your request or your questions, you are entitled to lodge a complaint with the competent authority in matters of Personal Information protection, the National Commission for Informatics and Liberties (CNIL), at the following Internet address:

- https://www.cnil.fr/fr/plaintes ;
- or to the following postal address: CNIL - 3 PLACE DE FONTENOY - TSA 80715 - 75334 PARIS CEDEX 07.


The text of the General Data Protection Regulation (GDPR) is freely accessible at the following Internet address: https://eur-lex.europa.eu/legal-content/FR/TXT/?uri=CELEX:32016R0679; or on the CNIL website at the following internet address: https://www.cnil.fr/fr/reglement-europeen-protection-donnees as well as all applicable texts on the protection of Personal Information and protection of rights and freedoms on the Internet (https://www.cnil.fr ).

To understand your rights, you can also refer to the explanations provided by the Cnil here: https://www.cnil.fr/fr/les-droits-pour-maitriser-vos-donnees-personnelles.

We point out that in application of articles L.223-1 et seq. Of the Consumer Code, you can, if you are a consumer, object at any time to being canvassed by telephone, by registering for free on the site www.bloctel.gouv.fr.


If you have any questions, comments, or concerns regarding our Privacy Policy, please contact us at: contact@lobster-protocol.com

.Contact information for the Company is as follows:

- Company’s name: TLM SOLUTIONS,
- Registration number: 918 119 793 (Trade and Companies Register of Nanterre),
- Registered office: 6, rue des Bateliers, 92110 Clichy,
- Legal representative: Mr. Alexis MAILLEY (Président),
- Jurisdiction: France.