The term ‘Lecil’ or ‘us’ or ‘we’ refers to the owner of the website whose office is 617 West 7th St Los Angeles, CA 90017, US. Our company is registered in Belize under registration number 167908. The term ‘you’ refers to the user or viewer of our website.
- The content of the pages of this website is for your general information and use only. It is subject to change without notice.
- Neither we nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information and materials found or offered on this website for any particular purpose. You acknowledge that such information and materials may contain inaccuracies or errors and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law.
- Your use of any information or materials on this website is entirely at your own risk, for which we shall not be liable. It shall be your own responsibility to ensure that any products, services or information available through this website meet your specific requirements.
- This website contains material which is owned by or licensed to us. This material includes, but is not limited to, the design, layout, look, appearance and graphics. Reproduction is prohibited other than in accordance with the copyright notice, which forms part of these terms and conditions.
- All trademarks reproduced in this website, which are not the property of, or licensed to the operator, are acknowledged on the website.
- Unauthorised use of this website may give rise to a claim for damages and/or be a criminal offense.
- From time to time, this website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no responsibility for the content of the linked website(s).
- Your use of this website and any dispute arising out of such use of the website is subject to the laws of Belize and the Belize courts will have exclusive jurisdiction
• If you have any concerns about material which appears on our site, please contact [email protected]
Thank you for visiting our site.
1. Important information
In these Terms and Conditions, references to:
- us and we are to GLOBAL INVEST MANAGEMENT LTD., trading as Lecil. and
- customer, client, you and your, are to the person who opens an Account with us.
These Terms and Conditions contain important information about the Services. You should read them carefully before accepting them. If you do not understand anything, please email [email protected] and ask for further information.
Lecil is not investment portfolios provider. Lecil is not giving any investment advice. Lecil is an intermediary between the client and investment portfolio providing company. Lecil is not the receiver of client funds. Lecil is a site which helps investment portfolio providers to access client funds. Lecil site shows clients balances in investment provider portfolios. Lecil is not a financial service provider and has no financial license in any country.
The Agreement will become legally binding, and we will start providing the relevant Services to you when we receive (a) confirmation that your Account is complete, and (b) satisfactory answers to our anti-money laundering inquiries (see clause 8.3 below).
3. Services and General Terms
The Services are only available to residents from selected countries. Each investment plan has different rules for residents. In all plans, investing is available for persons, who has EU passport. Investing may and may not be available for residents from other regions, please contact our support team, to know if you are eligible for investing.
We will provide you with some or all of these services, under the terms of the Agreement:
- Simplified Advice about which Lecil portfolio is right for you;
- discretionary investment management of the investments we hold on your behalf (your Portfolio);
- safe custody of your investments;
- intermediary service between you and investment fund providers.
4. Customer Categorisation
If we provide a Service to you, we will assume you are a retail client, and you will benefit from the protections available to retail clients under the rules in the FCA’s Handbook of Rules (FCA Rules).
If you hold an Account jointly, we will treat each of you as our customer.
If you are the trustees of a trust, we will treat each of you as our customer, instead of the beneficiaries of the trust.
If you are the agent of someone else, we will treat each of you and your principal as our customer.
In each of these cases, we will be entitled to take our instructions from any one customer, as if they were given by all of our customers; if we make a payment to any one customer, it will be treated as if we made it to all of our customers; and if a customer has an obligation to us, we will be entitled to require each and every customer to meet or satisfy that obligation on behalf of every other customer.
5. Simplified Investment Advice
We give Simplified Advice using a streamlined process to meet straightforward investment advice needs. You accept that Simplified Advice is only appropriate if (a) you do not need to reduce your debts; (b) you already have a reasonable amount put aside for emergencies; (c) you already have insurance to protect your family, if something happens to you; (d) you can meet your immediate financial needs; and (e) you still have some disposable income or capital to invest.
Our advice is restricted to the specific need expressed for your investment plan. When ensuring the advice is suitable, we will not consider your wider financial needs or circumstances, or the financial products you may already have. We only advise you about Lecil products and Services. We do not consider other products and services that might be suitable or more suitable for your needs.
We can help you transfer other investments into your Portfolio, but we will only do this if you ask. We do not advise on the suitability of investments we do not manage.
6. Discretionary Management Service
We are not the providers of fund management service. When choosing investment plan from our site, we will be connecting your funds to an investment company, which will manage your funds. The actual investment service provider who manages your portfolio will be referred as they or them in following clauses.
We are not the providers of fund management service. We don’t have the financial institution license and we are not applying to it. If you are applying to one of the investment plans we provide, then you are not investing your funds with us. You are not transferring your funds to us. Your funds will be not connected to us in any way and we don’t have the control over your funds. We don’t have your funds when you will invest in any of our investment plans. Your Account includes the information you have given us about (a) you; (b) your financial circumstances; (c) your knowledge and experience of investments and investing; (d) your attitude to risk; and (e) your investment objectives (your Information). We will use your Information to manage your Portfolio. You may change your Information at any time by updating your Account, although we reserve the right to amend the Agreement if you do. You accept that we will treat the Information as accurate and complete, unless and until you change it by updating your Account.
We will not manage your Portfolio. The portfolio will be managed by an investment company, which is one of our partners. They will manage your funds on a discretionary basis, using the Information to help us. They will manage each pot in your Portfolio with reasonable care and skill. You authorize them to enter into any kind of arrangement or transaction on your behalf. They may invest any amount or any proportion of your Portfolio in any one investment or investment type, and we may do so in any currency, and on any market.
If they decide to buy or sell an asset on your behalf, they will use the Information to decide if the proposed transaction is suitable for you.
We will provide you with a suitability report which explains our Portfolio management strategy, and we will amend that report if the Information changes.
They may make common investment decisions, which apply to a number of customer portfolios including yours.
You accept that they cannot guarantee the performance of any particular investment; that investments carry risks; and the risks include those described in section 48.
If you send them money, without telling us which plan you want to pay it into, they reserve the right to allocate it to your/one of your pot/s.
7. Initial and Minimum Investment
The minimum investment for each investment plan is:
If you make a withdrawal from your account and your balance will become lower than the minimum investment amount, then we will be freezing your investment account until new deposit or withdrawal is made.
8. Your Information
To be a Lecil customer you must be at least 18.
To open an Account, you must be (one of) the named holder(s) of an International bank account (IBAN account).
We are required to verify your identity when you join Lecil, and periodically thereafter. When we do this, we may use your personal data (as that phrase is used in and defined by European law) to carry out electronic searches on private and public databases. We will keep records of the information we obtain, when we do this. We may use credit reference agencies, and they will record the fact that an enquiry has been made. You accept that we may do each of these things, and that our use of credit reference agencies will generate a record of this kind. In some cases, we may need to ask for additional information or documents from you. If this happens, we will send you a secure email and you agree to provide us with the information and documents we ask for within a reasonable period. You accept that if you do not do this, we may freeze your Account or take other action against you or with respect to your Account.
The base currency of your Portfolio is United States Dollar.
We are providing investing plans where different companies manage your funds in different locations. Your funds will be managed by them in assets which is described in each investment plan web-page.
They may invest in fixed interest securities issued by governments, governmental bodies, quasi-governmental bodies, local authorities, and corporate bodies in the USA and overseas.
They may invest in authorized and unauthorized collective investment schemes in the USA and overseas.
They may invest in equities, including investment trusts, listed on recognized stock exchanges in the UK (e.g., the London Stock Exchange) and other countries (e.g. the New York Stock Exchange).
10. Best execution
Under the terms of the Markets in Financial Instruments Directive (“MiFID”), we are required to put in place an order execution policy and to take all reasonable steps to obtain the best possible result on behalf of our clients when executing orders.
Quality of Execution
We are not a discretionary investment manager. We are not aggregating all client orders and won’t trade on a consolidated basis.
When executing these orders, we are not going to take all reasonable steps to achieve the best execution. We have no procedures designed to obtain the best possible result for you.
An investment company, who will become managing your funds will take all reasonable steps to achieve the best execution. They have procedures designed to obtain the best possible result for you.
They will determine the best possible result by considering the price of the relevant investment, and the total cost of buying or selling it.
In executing an order under our execution policy, they will take into account the following execution factors, based upon the following priority:
- Size and nature of the order—to determine the most relevant execution platform/trading method;
- Likelihood of execution and settlement—to evaluate which counterparties Lecil should engage with;
- Price—Lecil will only accept the best available price when dealing with multiple counterparties
- Speed—When offered two equal best prices, the price offered first will be accepted
- Cost—Will be considered to evaluate what give the best possible net outcome, and
- Any other relevant considerations.
When executing a customer order, we will take into account the following criteria for determining the relative importance of the execution factors:
- The characteristics of the customer including the categorisation of the customer
- The characteristics of the customer order
- The characteristics of the financial instrument that are the subject of that order
- The characteristics of the execution venue to which that order can be directed
They will use their discretion to determine the appropriate execution venue for a trade, which may include, without limitation, an exchange, multilateral trading facility or a broker.
They will only execute trades on a regulated market or multilateral trading facility.
Review and Monitoring
We will review the effectiveness of our order execution arrangements (including the venues that we use) and the execution policy on an annual basis (and also on an ad hoc basis in response to any material change affecting a relevant execution venue). We will monitor our compliance with the policy, making enhancements to it or to our order execution arrangements where necessary and advising you of such changes and/or our on-going compliance with the policy, as appropriate.
In exceptional circumstances, such as technical faults leading to loss of connections with an execution venue, we may have to use other execution methods than those listed above.
Trades are made every day, except Sunday. Customers balance will be updated twice a week.
11. Client Money
If we hold uninvested money for you, we will take reasonable steps to identify a bank with a competitive interest rate and deposit that money with that bank (the Bank), together with other clients’ money. The rate of interest payable on that account will be determined by the Bank. However, the amount that is credited to your Account will be determined by the Bank and us, and we will tell you what it is from time to time. Any interest will be calculated on a daily basis and paid to your Account every six months. We may decide not to pay this interest to your Account until it reaches a minimum threshold.
Your money is held in a designated client bank account by the Bank, in compliance with the FCA Rules. This means, amongst other things, that our Client Money Bank will hold your money in a designated client bank account which is an account kept separate from our own funds.
When considering which Client Money Bank to use, we will exercise due skill, care and diligence and will periodically review the adequacy and appropriateness of any bank or credit institution where your money is deposited and of the arrangements for holding your money. It is important to note that we are not responsible for any acts, omissions or default of a credit institution or bank chosen by it but only for taking care in its choice and monitoring.
Your money may be pooled with money belonging to our other clients. If it is, you will not have a claim for a specific sum in a specific account. Your claim would be against the pool and, if there is a shortfall, you would share pro rata in that loss.
The designated client bank account may be outside the USA if the Bank has confirmed that (a) it holds the money in that account as trustee; and (b) it is not entitled to combine or set off that money in any way. Even so, if the Bank cannot or does not meet its obligations, the money in that account may not be treated in the way that it would have been treated, if the account had been held in the USA.
We may pass your money to a settlement agent outside the USA. If the agent cannot or does not meet its obligations, your money may not be treated in the way that it would have been treated if the settlement agent was in the USA.
If any money held by the Bank is unclaimed after 6 years, we may stop treating it as your money and include it in our own assets. We will only do this after we have taken reasonable steps to trace you and return the money to you. If you later show a valid claim to this money, we may pay you what you are owed.
If we undertake a transaction, and that involves transferring your money or investments to an exchange, clearing house, broker, settlement agent or other relevant party as Margin, Collateral or for another reason, your money or investments may be at risk. You accept that this is the case.
We are not obliged to tell you before terminating our relationship with the Bank and appointing a replacement; but we will tell you, if we do.
Income earned on the investments held in your Portfolio, which is payable to you, will be remitted to your Portfolio and may be reinvested.
If we are declared insolvent, your investments will be sold. We will make reasonable efforts to obtain the best market price for you.
Cash held outside a tax wrapper will be returned to your Bank Account. Our nominated custodian will contact you within 90 days of the declaration of insolvency about the cash held in a tax wrapper.
If Lecil and our nominated custodian are declared insolvent, you will need to register a claim with the FSCS, if applicable.
In this section, “we” is the final receiver of your funds (investment company), who will be your funds manager.
We accept payments from any bank account, which you are authorized to use, by debit card; direct debit; and bank transfer.
We accept payments with cryptocurrencies, such as Bitcoin, Litecoin, Then your payment will be processed by a third party that is subject to the Payment Services or Electronic Money Regulations.
When you make a payment by debit card or direct debit, your payment will be processed by a third party that is subject to the Payment Services or Electronic Money Regulations. These payments typically take 3 business days to reach us (with a maximum of 7 business days), during which time the money is held by the relevant service provider in an account protected by the relevant regulations.
Funds are directly debited to investment portfolio provider bank account. Lecil has no position in transferring funds. Lecil has no control over your money.
15. Source of Funds
We are obliged to comply with the Money Laundering Regulations. To do that, we may occasionally need to ask for proof that a payment received by us has originated from your Bank Account. We may also have to ask for evidence that your wealth is from a legitimate source. If we make what we regard as a reasonable request for these purposes, you agree to comply with it.
In this section, “we” is the final receiver of your funds (investment company), who will be your funds manager.
We will only pay money to the IBAN Bank Account. If you request a withdrawal within 60 calendar days of a debit card payment we reserve the right to return the funds to source.
If you cancel a direct debit or debit card payment after we have claimed or received the funds, we will return the money and debit your Account. If we need to sell some of your assets to settle amounts outstanding on your Account, we will do so, and you may incur a profit or loss. If your Account becomes overdrawn, we will ask you to settle that overdraft, and you agree to do so within a reasonable period.
We typically only transfer cash to or from you. In exceptional circumstances where we agree to transfer an account ‘in-specie’, we will levy a charge per investment (line of stock). The charge is included in the Schedule of Fees.
We reserve the right to only make external payments to and to accept payments from the bank account stated in your Account.
17. Data security
In order to provide Services to you we need to collect, use, share and store personal financial information about you, including your personal information. We make every effort to protect the privacy of our customers’ personal information. Other than as set out below, your personal information will not be disclosed, transferred or sold to any third party for any purpose.
You authorise us to use any of your personal information which is relevant to our provision of Services to you for all reasonable purposes in relation to your Portfolio. We may retain and continue to process your personal information after the termination of the Agreement or any other agreement between you and us. Your personal information may be transferred or disclosed to third parties where necessary. This enables us to provide Services to you and to discharge our obligations to third parties, including relevant stock exchanges, government agencies and regulators. Your personal information may be transferred outside of the European Economic area.
With your consent, your personal information may be used by us in order to provide you with information and marketing materials in relation to our other products and Services. By entering into the Agreement, you confirm your wish for your personal information to be processed for these additional purposes. If you do not wish your personal information to be processed in this way, please notify us by email.
You can request copies of your personal information held by us or any service provider we appoint to provide you with the Services under the Agreement by contacting us at [email protected] . We reserve the right to charge a fee for providing you with this information. You should notify us if any of the information held is incorrect.
If you have been introduced to us by one of our partner organisations, you authorise us to share your personal information with them.
Occasionally we may receive requests from third parties, such as financial advisers, for information that we hold on file for you. These requests are often coupled with a lengthy questionnaire requesting details of your holdings with us. In this instance we will verify the documentation sent to us and supply the relevant information. We will inform you via email that we have released your information and if there is any doubt about the validity of the request, we will always seek your confirmation by email before passing over any information.
We may communicate with you at any time including, when appropriate, by telephone or by email.
You can give us instructions and notifications about your Portfolio using email or our website. We are not obliged to act on an instruction. If we do act on an instruction, we will do so as soon as reasonably practicable after we have received it.
We may act on any instruction or notification we believe in good faith is from you, without carrying out any further checks or investigations. We will not be liable for following an instruction or notification which is not genuine; or for investigating, not investigating, or not following any instruction or notification that we believe may not be genuine. We will not be liable for any error of transmission or misunderstanding, or for the fraud of any other party (except in the case of our negligence, wilful default or fraud as described in section 28 below). We are not obliged to acknowledge receipt of your instructions.
We will send all notices, information and other correspondence to you by email to the email address set out in the Client Agreement Form or designated by you in your Account. If we send you a letter, it will be addressed to you at the postal address set out in the Client Agreement Form, or in your Account, and will be deemed to be delivered on the second business day after posting.
We record and monitor the telephone conversations and electronic communications that we have with you. We will store these records for at least seven years, during which they will be available to you on request.
We cannot guarantee that electronic communications will be successfully delivered to you, or that they will be secure and virus free. We will not be liable for any loss, damage, expense, harm or inconvenience caused as a result of an email being lost, delayed, intercepted, corrupted or otherwise altered or for failing to be delivered for any reason beyond our reasonable control.
All communications in relation to the Services will be in English.
19. Statements and reports
If we provide discretionary management services to you, we will send an electronic statement and valuation report every quarter.
If your employer requires confirmation that we have provided discretionary management services to you, we will provide this electronically, free of charge. If an original signed copy letter is required, we can write to you. Requests to issue certification letters should be sent to us by email.
We accept responsibility for any loss, damages or costs suffered or incurred by you only to the extent that such loss arises directly from our gross negligence, wilful default, fraud; and/or the breach of any duties which we owe you under FSMA, rules and regulations made under FSMA or FCA Rules. We will not be liable for any other losses, damages or costs suffered or incurred by you.
We will take reasonable care in the assessment and appointment of Sub-Custodians, pension scheme administrators, bankers, counterparties, agents and other third parties. We accept responsibility for any loss, damages or costs incurred by you only where these arise from our, negligence, wilful default or fraud in the assessment or appointment of such persons. We will not be responsible in any other circumstance for the actions of any such third parties.
All tax matters relating to your own tax position are your own responsibility and we have no responsibility towards you with regard to your personal tax position.
You will be liable to us for any cost, expense, loss or any damage incurred by us (including but not limited to professional advisors’ fees) arising from your breach of the Agreement, and/or your negligence, wilful default or fraud.
21. Force Majeure
We will not be held responsible for failing to fulfil our contractual obligations as a result of any situation, condition or event beyond our reasonable control (Force Majeure Event).
A Force Majeure Event may include but is not limited to an act of Parliament, an act of God, acts of terrorism, strike or riot, extreme movements in the price of a security, the breakdown of communication or electronic equipment or anything else that may reasonably impede our ability to act in line with the Agreement.
We will take all reasonable steps to act in your best interests when a Force Majeure Event occurs and may suspend or alter part or all of the Agreement, to the extent that we can no longer comply with the terms in question.
22. Amending the Agreement
We may amend the Agreement by giving you 10 business days’ notice by email. If we are required to amend these Terms and Conditions or the Agreement for reasons of compliance with the FCA Rules, or any other applicable law or regulation, however, we may do so with immediate effect.
You do not have the right to assign or transfer your rights or obligations under the Agreement to any other party.
We may assign our rights and obligations under the Agreement at any time. We will tell you before such an assignment takes effect.
24. Governing Law
The Agreement and any dispute or claim arising out of or in connection with it will be governed by and construed in accordance with the law of Belize
The parties irrevocably agree that the courts of Belize will have exclusive jurisdiction to settle any dispute or claim that arises out of or in connection with the Agreement.
25. Third Parties
A person who is not a party to the Agreement cannot enforce or enjoy the benefit of any of its terms under the Contracts (Rights of Third Parties) Act 1999.
26. Closing Accounts
You may terminate the Agreement at any time, by giving 30 days’ notice by email or through the website, subject to the settlement of all outstanding transactions. The charges within the Schedule of Fees will apply. We may pass on to you charges levied by third parties as a result of the termination of the Agreement. Transactions already in progress will be completed in the normal course of business.
We may terminate the Agreement by giving you 10 days’ notice by email, subject to the settlement of all outstanding transactions.
On termination of the Agreement, we will, following payment in accordance with clause 26.1 and settlement of all outstanding transactions, re-register your assets and transfer your cash as you reasonably request. If you make no reasonable request, we will take steps to re-register your assets in your name and to transfer your cash to you at our discretion.
After you close your Account, it is possible that further monies may reach your account (for example, dividend payments). However, if the balance of your account is less than $250, six years after the closing of your Account and we have made at least one attempt to contact you to which you have not responded within 28 days, we reserve the right to pay that small balance to a registered charity of our choice.
After you close your Account, it is possible that further monies may reach your Account (for example, dividend payments). However, if the balance of your Account is less than $10, six months after the closing of your Account, we reserve the right to pay that small balance to a registered charity of your choice.
27. Inactive Accounts
We will mark any Account as dormant if it has been inactive for at least one year to protect both you and us. If you ask us, we will tell you how you can access your Account. If you have money in a dormant Account, it will remain your property (or if you die it will form part of your estate).
28. Fees and Charges Schedule
Our fees and charges are calculated as a percentage of your profit earned when selling investment position.
7% on all profits. Example. Invested 100’000.00 US dollars, earned 6% profit in January. Profit would be 6’000 US dollars. Fee is 7% from earned 6’000 US dollars. Total fee amount is 420 US dollars. Client will receive 5’580 US dollars profit, instead of 6’000 US dollars.
Our quoted fee is inclusive of VAT.
By default, we will always return money to the bank account you registered with us. If you requested a withdrawal within 60 calendar days of a debit card payment we reserve the right to return the funds to the source.
When you cancel a direct Card payment (“chargeback”), we will debit your Account by the amount being reimbursed. In the event that there is insufficient money in your Account, we will convert assets in your account into cash as required and hold you liable if the account is in debt.
Withdrawal fee is 6% of the amount. You can request a withdrawal in 10 different currencies. 6% fee includes currency conversion fees and all the bank fees. Example. If you want to withdraw 10’000 US dollars, then the fee is 600 US dollars. You will receive 9’400 US dollars into your bank account, instead of 10’000 US dollars.
We have right to change the terms any time.
For questions, please contact us by email [email protected]