T&C / Lillion

Lillion Trust is the vehicle holding assets for third parties working with investors and subsidiaries companies.

Our independence and experience enables us to bring an objective perspective to the complexities of wealth administration and through our network of international offices we have particular expertise in providing services to private clients worldwide.

Lillion’s Private Client Services team provides a comprehensive range of solutions to a diverse global client base, underpinned by a commitment to innovation, differentiation and client service excellence.” We are also driving innovation in the sector through crypto industry offers powered by our proprietary Edge technologies. This provides a unified and holistic approach to organising a client’s wealth and related affairs, bringing together all the relevant aspects of their financial affairs through our purpose-built, secure trustee service.

The Legal Structure

Asset Management structure, a full crypto investmnet portfolio.

This entity can be used to manage Cash, Securities or any type of assets for clients worldwide. Turn-key packages.

The Trust Assets

There are no limitations on the types of assets that can be placed under management by a Trust Company. Assets can include but are not limited to:

  • Crypto Deposits (No Currency Restrictions)
  • Stocks
  • Bonds
  • Debentures
  • Mutual Funds
  • Hedge Funds
  • Any type of Securities including structured products
  • Commodities
  • Precious Metals
  • Real Estate
  • Investments in General


These terms and conditions apply between you and Lillion Trust, the owner and operator of this platform.

Please read these terms and conditions carefully, as they affect your legal rights. Your agreement to comply with and be bound by these terms and conditions is deemed to occur upon your first use of the Website.

If you do not agree to be bound by these terms and conditions, you should stop using the Website immediately.

In these terms and conditions, User or Users means any third party that accesses the platform and is not either (i) employed by Lillion Trustand acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Lillion Trust and accessing the platform in connection with the provision of such services.

You must be at least 18 years of age to use this Website. By using the platform and agreeing to these terms and conditions, you represent and warrant that you are at least 18 years of age.

Intellectual property and acceptable use

1. All Content included on the Website, unless uploaded by Users, is the property of Lillion Trust, our affiliates or other relevant third parties.

In these terms and conditions, Content means any text, graphics, images, audio, video, software, data compilations, page layout, underlying code and software and any other form of information capable of being stored in a computer that appears on or forms part of this Website, including any such content uploaded by Users.

By continuing to use the Website you acknowledge that such Content is protected by copyright, trademarks, database rights and other intellectual property rights. Nothing on this site shall be construed as granting, by implication, estoppel, or otherwise, any license or right to use any trademark, logo or service mark displayed on the site without the owner’s prior written permission

2. You may, for your own personal, non-commercial use only, do the following:

– retrieve, display and view the Content on a computer screen

3. You must not otherwise reproduce, modify, copy, distribute or use for commercial purposes any Content without the written permission of Lillion Trust.

Prohibited use

4. You may not use the platform for any of the following purposes:

– in any way which causes, or may cause, damage to the platform or interferes with any other person’s use or enjoyment of the platform;

– in any way which is harmful, unlawful, illegal, abusive, harassing, threatening or otherwise objectionable or in breach of any applicable law, regulation,  governmental order;

– making, transmitting or storing electronic copies of Content protected by copyright without the permission of the owner.

Links to other website

5. This platform may contain links to other sites. Unless expressly stated, these sites are not under the control of Lillion Trust or that of our affiliates.

6. We assume no responsibility for the content of such Websites and disclaim liability for any and all forms of loss or damage arising out of the use of them.

7. The inclusion of a link to another site on this Website does not imply any endorsement of the sites themselves or of those in control of them.

Privacy Policy

8. Use of the platform is also governed by our Privacy Policy, which is incorporated into these terms and conditions by this reference.

Availability of the platform and disclaimers

9. Any online facilities, tools, services or information that Lillion Trust makes available through the platform (the Service ) is provided “as is” and on an “as available” basis. We give no warranty that the Service will be free of defects and/or faults. To the maximum extent permitted by the law, we provide no warranties (express or implied) of fitness for a particular purpose, accuracy of information, compatibility and satisfactory quality.

Lillion Trust is under no obligation to update information on the platform.

10. Whilst Lillion Trust uses reasonable endeavours to ensure that the platform is secure and free of errors, viruses and other malware, we give no warranty or guaranty in that regard and all Users take responsibility for their own security, that of their personal details and their computers.

11. Lillion Trust accepts no liability for any disruption or non-availability of the platform.

12. Lillion Trust reserves the right to alter, suspend or discontinue any part (or the whole of) the Website including, but not limited to, any products and/or services available. These terms and conditions shall continue to apply to any modified version of the Website unless it is expressly stated otherwise.

Limitation of liability

13. Nothing in these terms and conditions will: (a) limit or exclude our or your liability for death or personal injury resulting from our or your negligence, as applicable; (b) limit or exclude our or your liability for fraud or fraudulent misrepresentation; or (c) limit or exclude any of our or your liabilities in any way that is not permitted under applicable law.

14. We will not be liable to you in respect of any losses arising out of events beyond our control, the trust is reliable for its customers only for assets custody under the Swedish regulation.

15. To the maximum extent permitted by law, Lillion Trust accepts no liability for any of the following:

– any business losses, such as loss of profits, income, revenue, anticipated savings, business, contracts, goodwill or commercial opportunities done by direct or undirect clients;

– any special, indirect or consequential loss or damage.

16. You may not transfer any of your rights under these terms and conditions to any other person. We may transfer our rights under these terms and conditions where we reasonably believe your rights will not be affected.

17. These terms and conditions may be varied by us from time to time. Such revised terms will apply to the platform from the date of publication. Users should check the terms and conditions regularly to ensure familiarity with the then current version.

18. These terms and conditions together with the Privacy Policy contain the whole agreement between the parties relating to its subject matter and supersede all prior discussions, arrangements or agreements that might have taken place in relation to the terms and conditions.

19. If any court or competent authority finds that any provision of these terms and conditions (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of these terms and conditions will not be affected.

20. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

21. This Agreement shall be governed by and interpreted according to the law of Singapore and all disputes arising under the Agreement (including non-contractual disputes or claims) shall be subject to the exclusive jurisdiction of the Singapore courts.

22. Lillion Trust is regulated by the Singapore Reg in the carrying on of trust company business.  ‘Lillion’ in the following terms of business means, Lillion Trustor any of its subsidiary companies.

These terms of business apply to all relationships, whether the provision of trustee services, the provision of company administration services or otherwise unless specifically excluded or amended in writing.   These Terms of Business will apply to all existing relationships from 1 January 2021 (or earlier if so agreed).

Lillion Trust, in providing any service, whether to a company, trust or individual, shall not do anything or be required to do anything which in Lillion’s opinion a) may conflict with the laws or regulations of Singapore or, as appropriate the company’s memorandum and Articles or Association or the trusts governing instrument(s)

b) would expose Lillion Trustor any of its agents, officers or employees to any risk of civil or criminal liability or prosecution in any part of the world.

23. Taxation : Lillion Trust is not and does not hold itself out as being an expert in or have knowledge of the laws or regulations of any jurisdiction other than Singapore and in particular, Lillion does not provide advice on matters relating to taxation in any jurisdiction other than Singapore.

24. Client monies : Funds paid to Lillion Trust by a client may be received in to the Lillion Trust clients’ account.  All monies transferred to or held by Lillion or any Service Provider in relation to an Entity and/or the Client in relation to that Entity other than in respect of fees, taxes and disbursements shall accrue interest at the rate, if any, payable by the relevant client account bankers. Such interest shall be calculated and accrued on a quarterly basis in arrears and, if such amount exceeds the sum of SGD500, such quarterly interest shall be credited to the account in which the monies are held on behalf of the Entity and/or the Client. Where, however, the interest earned in a calendar quarter is less than SGD500, the amount of interest shall be retained by Lillion or any of its Subsidiaries and Affiliates in respect of the administrative costs of arranging for the holding of the monies and the calculation and accrual of the interest earned thereon    Lillion reserves the  right to charge an administration fee  in respect of holding money on client account, in  addition to any other fees charged.

25. Communications : Communication between Lillion Trust and the beneficial owner, settlor or beneficiary of any client entity may be made by letter, fax, email or telephone to the address or number for that person which has most recently been notified to Lillion in writing.  Lillion Trust makes no guarantee of the security of any particular form of communication and accepts no responsibility or liability for such. If any person does not wish Lillion Trust to communicate by any particular form of communication a written instruction must be received to that effect. Lillion Trust reserves the right to monitor and/or record communications in any form.

26. Confidentiality : All information which is not in the public domain concerning the entity under administration and any transactions or matters which it may be engaged in will be kept confidential by Lillion and all its officers and employees unless

a. it is necessary to disclose them by virtue of a Swedish law or by order of the Swedish Courts or any other order which has legal effect in Singapore, or

b. such disclosure is considered necessary or appropriate in the interests of the company or the beneficiaries of a trust, or

c. disclosure is authorised by an appropriate party.

27 Storage of documents and records : After termination, for whatever reason, of the provision of services to a client entity, Lillion Trust is entitled to retain all records and documents generated in the course of providing such services until all fees and disbursements have been settled in full.   Where a successor has been appointed to take over the service provided to the client entity, Lillion Trust will liaise with that successor to provide such original or copy documents as may reasonably be required.   Copies of all documents will be retained by Lillion Trust .  Lillion Trust reserves the right to charge the cost of copying such documents where considered appropriate. After the termination of the provision of services Lillion Trust will retain all records and documents generated and files relating to the client entity and the services provided for at least ten years.  At Lillion Trust Company Limited’s discretion, such retention may be by way of electronic copies, save for original signed documents,  Where electronic copies have been made, Lillion Trust reserves the right to destroy the related hard copies.   After ten years, the retention of all documents is at the discretion of Lillion Trust and they may be destroyed without further notice to any concerned party unless Lillion Trust has been instructed otherwise prior to the termination of the service.  If instructed to retain files for longer than the ten year period, a charge may be made for storage.

Specific requests for information concerning the services or the retrieval of specific documents may be made after the termination of the services by any person entitled to such information, but Lillion Trust reserves the right to charge for retrieving the information.

28 Identity of clients and anti-money laundering procedures : Swedish law requires Lillion Trust to operate anti-money laundering polices and procedures in carrying on trust and company administration business.    Lillion Trust reserves the right to apply such checks as it considers necessary or appropriate (including but not limited to the confirmation of source of funds, verification of the identity (including address) of beneficial owners, settlors, beneficiaries and verification of the capacity to give instructions for limited companies).  Failure to provide information or documents requested to allow Lillion Trust to carry out these checks shall allow Lillion Trust to terminate or suspend the services provided.  No responsibility or liability which arises directly or indirectly as a result of delays or termination of services resulting from these checks shall be accepted by Lillion Trust.   Information or documents provided to fulfil these requirements may be subject to disclosure and production as a result of orders effective under Singapore law.

It may be necessary to disclose information or documentation arising from anti- money laundering procedures to third parties, such as banks, which provide services to a client entity.   By providing the required information, each person concerned will be taken to have consented to the onward disclosure of such information to third parties.

29. Variation and publication of Terms of Business : Lillion Trust reserves the right to vary these terms of business from time to time including during the provision of services to a particular entity.    Where the terms of business are varied, Lillion Trust will use reasonable efforts to draw the variation to the attention of existing clients. A hard copy of the Terms of Business in force at any particular time will be provided on request.   However, these Terms of Business and any future variations thereof will be published on the Lillion Trust website by way of public notice to all existing and potential clients of Lillion Trust Company Limited.  Where written notice of the existence of these Terms of Business as published on the website has been given to any person, and they have not requested a hard copy be sent to them, they shall be deemed to have agreed to the Terms of Business and future variations.

30. Services provided by associated entities and other agents : Where it is considered appropriate, at the discretion of Lillion Trust, to seek legal or accountancy advice on any matter, Lillion Trust reserves the right to use the services of parent companies’advisors. Fees relating to such advice or services will be billed separately

Lillion Trust reserves the right to nominate any of its subsidiary companies or directors or employees to hold office or provide any part of the administration of the entity.   Lillion Trust reserves the right, wherever considered necessary or appropriate in providing the services, to delegate any of the responsibilities or functions to, or to seek advice from, any third party or agent, where this is not inconsistent with the terms of the relevant agreement or instrument governing the services concerned.   The fees and commissions of such third parties or agents may be shown as a disbursement on Lillion’s next invoice or be billed separately.

31. Working for other clients : Lillion Trust reserves the right to provide services to other client entities at its discretion.   Any agreement to provide services to a particular entity does not mean that similar services will not be provided for other entities, including in connected matters, or prevent directors or associated companies from acting for other parties to transactions in which the entity may be involved.  Where, in the course of providing any service, confidential information is disclosed to or held by us, such information will be adequately safeguarded and will not be used against the interests of the relevant client entity or beneficiaries thereof (in the case of a trust).   Lillion Trust reserves complete discretion to determine, in the case of any conflict of interest arising, whether to continue to act in all capacities concerned, with the consent of any relevant parties.  If it is considered inappropriate to continue to act in cases of conflict of interest, Lillion Trust reserves the right to cease to act in one or more such capacities, including termination of the provision of trustee services to any trust or of company administration services to any company.  If Lillion Trust decides to terminate services provided to any entity in these circumstances Lillion Trust shall not be liable for any expenses or losses arising from such termination, including but not limited to any loss arising from lost opportunities to the entity concerned or any related parties.

32. Questions and Complaints : Questions or concerns which arise in respect of services provided should initially be addressed to the director of Lillion Trust responsible for the client relationship concerned.  All queries or complaints, including concerns over fees will be answered fully and promptly.   If the issue is not satisfactorily resolved by this process, the issue may be referred to Lillion Trust Company Limited’s compliance officer who may refer them to a director not generally involved in the client relationship for an independent review.   A record of all complaints must be maintained by Lillion Trust as a requirement of the Codes of Practice governing trust company business.   This record is available for inspection by officers of the Singapore Financial Services Commission.  If any dispute cannot be resolved in the above way then the Courts of Singapore shall have exclusive jurisdiction to hear such dispute applying Swedish law in all such matters.   These terms of Business shall be governed by and construed in accordance with the laws of Singapore. Introduction :

Lillion is committed to conducting its business in an ethical manner and in compliance with all applicable laws and regulations, including the United States Foreign Corrupt Practices Act (FCPA), the United Kingdom Bribery Act (UKBA) and similar laws in other countries that prohibit improper payments for business advantage. This document describes Lillion’s policy prohibiting bribery and other improper payments in the conduct of Lillion’s business operations and the responsibilities of employees to ensure the implementation of this policy. Questions regarding the policy and its applicability to particular circumstances should be directed to Lillion Admin

Policy Overview

Lillion strictly prohibits bribery or any other inappropriate payment in the course of its business activities. This prohibition applies to all business activities, anywhere in the world, whether they involve government officials or other commercial enterprises. A bribe or other improper payment to secure a business advantage is never acceptable and may expose individuals and Lillion to possible criminal prosecution, reputational damage or other serious consequences. This policy applies to all employees of the company as well as to employees of the different companies linked to the company, including managers, employees and agents or other intermediaries acting on behalf of Lillion or any other company of the group.

Each officer and employee of Lillion has a personal responsibility and obligation to conduct Lillion’s business activities in an ethical manner and in compliance with all applicable laws in the countries where Lillion operates. Failure to do so may result in disciplinary action up to and including termination of employment.

Improper payments prohibited by this policy include bribes, kickbacks, excessive gifts or entertainment, or any other payment made or offered to obtain an improper business advantage. Such payments should not be confused with reasonable and limited expenses for gifts, business entertainment and other legitimate activities directly related to the conduct of Lillion’s business.

Lillion has developed a comprehensive program for the implementation of this policy through appropriate guidance, training, investigation and monitoring. The Compliance Officer, also Director of Operations, has overall responsibility for the trust, with the support of Lillion’s management. The Compliance Officer is responsible for advising on the interpretation and application of this policy, supporting training and education, and responding to reported concerns.

The prohibition of bribery and other improper payments applies to all business activities, but is particularly important when dealing with public officials. The following summary is intended to provide personnel engaged in international activities with a basic knowledge of the applicable rules in order to avoid unintentional violations and to recognize potential problems in time for them to be properly addressed.

What’s illegal?

The FCPA, UKBA and other state agencies have enacted anti-corruption laws that make it illegal to bribe a foreign official to obtain an “improper business advantage”. Undue commercial advantage may involve efforts to obtain or retain a contract, such as in the awarding of a government contract, but may also involve regulatory measures such as the granting of licenses or permits. Examples of prohibited regulatory corruption include paying a foreign official to ignore an applicable customs requirement.

A violation may occur even if an improper payment is only offered or promised and is not actually made, if it is made but does not achieve the desired result, or if the result benefits someone other than the licensor (e.g. by directing the business to a third party). In addition, it is of little consequence if the official or employee could have suggested or demanded the bribe, or if a business believes that it is already entitled to government action.

Who is an “official”? An “official” can be essentially any person who exercises government authority. This includes any official or employee of a government department or agency, whether in the executive, legislative or judicial branches of government, and whether at the national, state, local or international level.

Civil servants and employees of public or state-controlled enterprises are also covered, as are private citizens acting in an official government capacity. Civil servant status will often be apparent, but not always. In some cases, individuals may not consider themselves to be public officials or be treated as such by their own government, but nevertheless exercise an authority that would make them “public officials” for the purposes of anti-corruption laws. Personnel engaged in sensitive activities are responsible under this policy for inquiring whether a proposed activity might involve a public official or an entity owned or controlled by a local or foreign government, and should consult with the compliance officer when questions about status arise.

What types of payments are prohibited? The FCPA prohibits offering, promising or giving “anything of value” to a public official to obtain an improper commercial advantage. In addition to cash payments, “anything of value” may include :

  • Gifts, entertainment or other commercially promotional activities;
  • Payment or reimbursement of expenses to an employee;
  • Offers of employment or other benefits to a family member or friend of the employee;
  • Contributions from political parties and candidates;
  • Charitable contributions and sponsorships.

Other less obvious elements provided to a public official may also violate anti- corruption laws. Examples include in-kind contributions, investment opportunities, stock options or positions in joint ventures and favourable or directed subcontracts. The prohibition applies regardless of whether an item directly benefits the agent or another person, such as a family member, friend or


Under the law, Lillion and the individual officer(s) or employee(s) may be held liable for undue payments made by an agent or other intermediary if they know or have reason to know that a bribe will be paid. Deliberate ignorance, including failure to conduct a reasonable investigation in the event of suspicious circumstances, is not a defence and it is irrelevant whether the intermediary is itself subject to anti-bribery laws. All employees should therefore be alert to potential “red flags” in transactions with third parties.

Lillion and its subsidiaries must maintain accurate books and records that reflect transactions and asset disposals in reasonable detail, supported by an appropriate system of internal accounting controls and our software Ebanq. These requirements are implemented through Lillion’s standard accounting rules and procedures that all personnel are required to follow without exception. Particular attention is paid to transactions that may involve payments to local or foreign government officials. Off-book accounts should never be used. Facilitation or other payments to government officials shall be promptly reported and properly recorded as to purpose, amount and other relevant factors. Requests for false invoices or payment of unusual, excessive or inadequately described expenses must be rejected and reported promptly. Misleading, incomplete or false entries in the books and records of Lillion are never acceptable.

  • Lillion has established detailed procedures for the selection, appointment and monitoring of agents, consultants and other third parties. These rules and procedures must be followed in all cases, paying particular attention to “red flags” that may indicate possible legal or ethical violations.
  • Due diligence typically includes appropriate reference and background checks, written contractual provisions that confirm a business partner’s responsibilities, and appropriate follow-up controls. Personnel working with agents and other third parties may indicate possible legal or ethical issues, commonly referred to as “red flags. The presence of red flags in a relationship or transaction generally requires the prior approval of an appropriate senior officer, a description of the nature and extent of services provided in a written contract, and appropriate contractual safeguards against potential violations of law or company policy.
  • This policy imposes specific responsibilities and obligations on all company personnel, which will be implemented through standard disciplinary measures and will be given due consideration by staff.
  • All employees and agents are responsible for understanding and complying with the policy in the course of their work. Every employee has an obligation to do so:

– Know the applicable aspects of the policy and communicate them to subordinates ;

– Ask questions if the policy or the actions to be taken in a particular situation are not clear enough;

– Be alert to indications or evidence of possible wrongdoing;

– Properly manage and control the business activities of third parties;

– Promptly report violations or suspected violations through appropriate channels.

Any employee who has reason to believe that a violation of this policy has been or may be committed, must promptly inform his or her supervisor, the next level of supervision or the Lillion compliance officer. Information will always be communicated on a confidential basis.

Retaliation in any form against an employee who has, in good faith, reported a violation or possible violation of this policy is strictly prohibited. Employees who violate this policy will be subject to disciplinary action up to and including termination of employment. Violations may also result in prosecution by law enforcement authorities and severe criminal and civil penalties.


When you interact with our Website, we may collect the following categories of personal information.

Information You Provide to Us

Registration and Your Information.

If you want to use certain features of the Website, you will have to create an account (“Account”) using your email address. You may also receive an invitation to proceed with the registration via the email used to register an account.

Accuracy of Account Information.

It is important that you provide us with accurate, complete and up-to-date information for your Account and you agree to update such information to keep it accurate, complete and up-to-date. If you don’t, we might have to suspend or terminate your Account. You agree that you won’t disclose your Account password to anyone, and you’ll notify us immediately of any unauthorised use of your Account. You’re responsible for all activities that occur under your Account, whether or not you know about them.

Communications with Us.

We collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, or otherwise communicate with us.

Interactive Features.

We may offer interactive features such as forums, blogs, chat and messaging services, and social media pages. We and others who use our Services may collect the information you submit or make available through these interactive features. Any content you provide on the public sections of these features will be considered “public” and is not subject to the privacy protections referenced herein. By using these interactive features, you assume the risk that the personal information provided by you may be viewed and used by third parties for their own purposes.

Information Collected Automatically.

Automatic Data Collection. We may collect certain information automatically when you use the Website. This information may include your registration date, Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, details about your browser, operating system or device, location information (including inferred location based off of your IP address), Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, information about how you interact with the Website, including the frequency and duration of your activities, and other information about how you use the Website. Information we collect may be associated with accounts and other devices.

Cookies, Pixel Tags/Web Beacons, and Analytics Information. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your device that allow us and our partners to record certain pieces of information whenever you visit or interact with our Website.

Cookies. Cookies are small text files placed in device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Website may not work properly.

Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Website which collects information about engagement. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Analytics. We may use Google Analytics and other service providers to collect and process analytics information on our Website.

For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the website by going to http://tools.google.com/dlpage/gaoptout.

Session Replay Providers. We use Hotjar for session replay analytics. Hotjar’s service allows us to record and replay an individual’s interaction with the Website. This helps us understand our user’s experience. For more information about Hotjar, please visit: https://www.hotjar.com/legal/policies/privacy. You can opt out of Hotjar’s processing of your information on our website by visiting: https://www.hotjar.com/legal/compliance/opt-out.


How We Use Automatic Collection Technologies. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services. Our uses of these Technologies fall into the following general categories:

Operationally Necessary. This includes Technologies that allow you access to our Website, applications, and tools that are required to identify irregular site behaviour, prevent fraudulent activity and improve security or that allow you to make use of our functionality;

Performance Related. We may use Technologies to assess the performance of our Website, including as part of our analytic practices to help us understand how our users use the Website;

Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Website.

Personal Information Use. Lillion shall use your personal information for a variety of business purposes, including:

To Provide Services or Information Requested, such as:

Initiating our contract with you;

Processing payment and/or other financial information to facilitate your use of the Services;

Responding to questions, comments, and other requests;

Providing access to certain areas, functionalities, and features of our Website;

Answering requests for customer or technical support.

Administrative Purposes, such as:

Pursuing legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

Measuring interest and engagement in our services;

Developing new products and services;

Ensuring internal quality control and safety;

Communicating with you about your account, activities on our Website and Privacy Notice changes;

Preventing and prosecuting potentially prohibited or illegal activities;

Enforcing our agreements; and

Complying with our legal obligations

Marketing Our Products and Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.  Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest- based” or “personalised advertising” including cross-device tracking.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time by emailing contact@lillion.org

Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

De-identified and Aggregated Information Use. We may use personal information and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

Consent and Explicit Consent:  Lillion relies on your consent and/or explicit consent to process your personal information as detailed in the acceptance of our Terms of Service.

Compliance with our Legal Obligations: Lillion may process your personal information to comply with our legal obligations.

Performance of a Contract: Lillion may need to process your personal information to fulfil an agreement to provide our Services to you.


Lillion does not share, sell, rent or loan Personal Information with independent third parties.  Nevertheless, we may access, preserve, and disclose any information we store in association with you to external parties if we, in good faith, believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our, or others’ rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation or prosecution of suspected or actual illegal activity. Under such circumstances where the law, a court order or other legal process prohibits notice prior to disclosure, none shall be provided.

We may share your personal information with the following categories of third parties:

Other Organisations at your Instruction. You may instruct Lillion to share your personal information, including your biometric data, with third parties for their own, independent purposes. Once you share your personal information with these parties, it will be subject to the privacy policy and practices of the receiving party. These third parties are not controlled by Lillion. We encourage our users to read the privacy policies of each third party with which they interact. We are not responsible for the privacy and security practices of such third parties. Disclosing your information to these third parties is at your own risk.

Service Providers. Lillion employs third party service providers. Where Personal Information is shared with a service provider each third party is required under contract with Lillion to secure all Personal Information with access permissions provided to only those employees who need it to complete a task on our behalf. The categories of service providers to whom we entrust personal information include service providers for: (i) the provision of information, products, and other services you have requested; (ii) marketing and advertising; (iii) payment and transaction processing; (iv) customer service activities; and (v) the provision of IT and related services.

Disclosure in the Event of Merger, Sale, or Other Asset Transfer. If we are involved in a merger, acquisition, financing due diligence, reorganisation, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.


All information processed by us may be transferred, processed, and stored in Lillion, which may have data protection laws that are different from the laws where you live. We endeavour to safeguard your information consistent with the requirements of applicable laws. Further details can be provided upon request.


General. You may have the right to opt out of certain uses of your personal information.

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms of Service or this Privacy Notice).

Mobile Devices. We may send you push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. With your consent, we may also collect precise location information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.


For purposes of the E-Consumer Privacy Act, we do not “sell” your personal information.

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) object to our processing of your personal information (v) restrict our uses of your personal information; (vi) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vii) withdraw your consent; and (viii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.

We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.


We store the personal information we receive as described in this Privacy Notice for as long as necessary to fulfil the purpose(s) for which it was collected, resolve disputes, establish legal defences, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. We will delete your data after 10 years of your last interaction with the Website.


We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable laws, we do not accept liability for unauthorised disclosure.

By using the Website, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Website. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an email to you.


The Services are not directed to children under 18(or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.


If you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with a supervisory authority in your jurisdiction if you believe our processing of your personal information violates applicable law.


We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use the Services after the new Privacy Notice takes effect.