Liberis (“Liberis” or the “Company”) recognizes, respects and protects the personal privacy rights of all our customers and works diligently to safeguard your privacy. We are committed to providing security and privacy regarding the collection and use of our customers’ personal information, as well as the personal information of all consumers who visit our institution.
1. What Information Do We Collect?
The types of personal information that we collect depends on the products and services you request and use. This information may include, for each Principal who is an individual:
Percentage of ownership in the business
Home street address
Social security number
Date of birth
We may also require written authorization from each Principal to obtain consumer credit reports.
We may also require the business to provide its name, postal and email addresses, and telephone numbers; type of entity such as corporation, LLC, partnership, or sole proprietorship; Employer Identification Number; the date the business was started; its bank and routing number and account number; its bank statements and its management and/or audited accounts.
We may require the business to provide its acquirer Merchant ID(s), the purpose for which it is requesting funding, its current and historical card takings, and chargeback and refund data, as well as its Merchant Category Code(s) and/or industry type.
We may require other reports such as credit, fraud and Office of Foreign Asset Control (“OFAC”) reports on each Principal.
We may require confirmation that the business is continuing to take payments through the card terminal(s) provided to us.
2. How we collect information
We may collect any personal information that you provide to us voluntarily, for example by completing a form on any of our websites or in hard copy, by taking part in survey, a phone or social media conversation, or by emailing us, or by permitting us to obtain information about you from a third party.
Our systems may automatically record information about your website usage, such as your browser type (e.g. Internet Explorer), operating system (e.g. Microsoft Windows), IP address (a way of identifying your internet connection) and basic information about your internet service provider. This information does not require your intervention and is used to improve our services and enhance your user experience.
For security and audit control, and to help us understand your preferences, we may also keep a record of when you access the site, which pages you visit and the actions you take on each page.
We may also collect data contained in a credit report from a consumer reporting agency (“CRA”) or from other information databases such as fraud and OFAC reporting sources.
3. How We Use Your Personal Information
3.2 Reasons we can use your personal information:
For everyday business purposes:
To register you as a user and to provide the services you require.
To decide whether to offer you a Liberis product or service.
To search CRA or other database records.
To provide you with customer support.
To enhance the accuracy of the information that we hold about you.
To notify you of any important changes to the site.
To prevent potentially prohibited or illegal activities.
To enforce our Terms and Conditions.
To enhance your experience on our website by
Monitoring and improving our services and customizing our website for you.
For marketing purposes:
To keep you informed of any products, services or offers which might be of interest to you where you have provided your consent for us to do so.
For internal research purposes, general website administration, and demographic and statistical analysis of our service users.
3.3 We may use your personal information to generate non-personal statistical data, for example relating to the size of our customer base and the levels of site usage. This will only be group data, such as the age range of site users, and will not include any information that could personally identify you. This may then be shared with third parties.
4. How we may share and disclose your personal information
4.1 Liberis shares your personal information with third parties as permitted by law, including in the following ways:
Third party service providers. We may work with third party service providers, including affiliates, to support our business functions, such as facilitating electronic fund transfers and offering customer service. For example, we will work with companies that we partner with to provide services to you, and companies that we work with to collect information about your card transactions. Liberis may share your personal information, including credit reports, with such companies, but all service providers acting on our behalf will only process your data in accordance with instructions from us and will comply fully with relevant data protection laws and any other appropriate confidentiality and security measures.
Credit reporting agencies. Liberis may share personal information about you with CRAs or other data-collection organizations to meet our reporting obligations.Other affiliates and third parties. We may also share your personal information, other than credit reports, with affiliates and third parties that are not affiliated with us for any legitimate purpose permitted by applicable law.
4.2 We may also share aggregated and anonymized data sets based on your personal information with third parties that does not reasonably identify you directly as an individual.
5. Cookies and Similar Technologies
To monitor site usage.
To keep an audit trail.
To understand visitors’ browsing habits.
To analyze trends and demographic statistics.
To compile statistical reports.
5.3 Most internet browsers accept cookies by default; however, you can usually change your browser settings to reject cookies if you would prefer not to receive them. If you choose not to receive our cookies you will not be able to receive any personalized features and you may not be able to benefit from all our services.
6. Information Security
6.1 The security of your personal information is very important to Liberis. We use physical, electronic, and administrative safeguards that are designed to protect your Personal Information from loss, misuse and/or unauthorized access, disclosure, alteration and destruction.
We have several layers of security measures in place to protect your information, including:
An up-to-date anti-virus software to protect against viruses damaging data and infrastructure,
Periodic review of our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems,
Housekeeping measures by regular backups, encryption, and network domain policy.
In addition, Liberis uses standard security protocols and mechanisms to exchange the transmission of sensitive data such as credit card details and bank account numbers. When you enter sensitive Personal Information such as your bank account number on our site, we encrypt it using Secure Socket Layer (SSL) technology.
6.2 Liberis is also committed to reducing risks of human error, theft, fraud, and misuse of its facilities. The Company’s efforts include training employees on security policies and procedures as well as implementation of such policies and procedures. Liberis employees are required to maintain the confidentiality of services data. Employees’ obligations include written confidentiality agreements, regular training on information protection, and compliance with company policies concerning protection of confidential information.
7. Protecting Children’s Privacy Online
Liberis’s website is not directed to individuals under the age of eighteen (18). We request that individuals under the age of eighteen do not provide Personal Information through our website. In the unlikely event that we learn that information from such individuals has been collected, we will immediately remove that information from our databases. The Company does not knowingly collect, use, or disclose personal information from or to children under age 13 without obtaining written, verifiable consent from a parent or legal guardian. For more information on the Children’s Online Privacy Protection Act, please visit the Federal Trade Commission website: http://www.ftc.gov/opa/reporter/privacy/coppa.shtml.
8. Using other websites
8.1 Our websites may contain links to web sites which are owned or controlled by parties other than Liberis Inc. These links are provided for your convenience and do not imply that we have reviewed or condone the third-party sites, their content, or their privacy policies.
8.2 When using other websites, you must be aware that any personal information you supply will be handled according to their privacy policies. We recommend that you read and consider these website’s privacy policies and terms and conditions before providing any of your personal information. Liberis is not responsible for privacy practices or content on third-party websites.
8.3 Our websites may also automatically transfer you to a third party site in order to fulfil the services we provide to you. In such cases, we will carry out due diligence to ensure third parties have the appropriate data protection requirements in place.
8.4 When you access the linked third party websites you do so at your own risk. These sites may place their own cookies or other files on your computer, or collect data or solicit personal information from you. Liberis is not liable for any misuse of your information or other misconduct by the third party.
For questions, contact us at firstname.lastname@example.org ,or call us at (844) 754-2370.
10. Your California Privacy Rights
10.1 California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com. Please note that we are only required to respond to one request per customer each year. We will not sell or share your Personal Information with non-affiliated companies for their direct marketing purposes without your consent.
Your privacy matters to us and we ensure that we comply with the General Data Protection Regulation and Data Protection Act 2018 when storing or processing your data.
It’s important to us that you understand which data we collect, and how we use it, so that you can make informed decisions about providing your data to us. This privacy notice (also sometimes referred to as a “Fair Processing Notice”) has been written to help you to do that.
In this notice “we” and “us” refers to the Liberis Limited and its respective subsidiary and/or affiliated group companies. Liberis Limited is the data controller for the purpose of the General Data Protection Regulation and Data Protection Act 2018. We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this Privacy Notice. You can find details of our registered address, as well as how to contact our Data Protection Officer with questions regarding data protection or privacy, at the end of this notice.
As Liberis Limited is based in the United Kingdom, we have appointed Liberis Sweden AB (company number 559205-5494) to be our representative within the EEA. Their contact details are Regeringsgatan 29, 111 53 Stockholm.
Many of the individuals about whom we collect personal data provide it to us as representatives of a company or other legal entity that they own or that they are engaged by. References to “your business”, “your account”, “your application”, “your enquiry” and other similar terms below, are deemed to include references to the business, account, application or enquiry of the entity that you represent, as applicable.
The data we collect
Data we collect, and how we use itOur lawful basis and purposes for processing your data
We always ensure that we have a fair and legal basis for processing your data. Below we have set out our lawful bases for processing your data at various stages in your journey with us, alongside our purposes for processing your data. Where we are relying on our legitimate interests to process your data, the purposes for processing set out below are our identified legitimate interests. You can find out more about the various lawful bases for processing on the ICO website, https://ico.org.uk/, if this terminology is unclear.
We request that where possible you do not provide us with special category / sensitive data (e.g. racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, or data concerning health, sex life or sexual orientation, or data relating to criminal convictions or offences). If we do receive such information, we endeavour to delete it where possible.
Data you provide directly to us
Categories of Data
Purposes of Processing
Your business name
(depending on the size of the business, this may not be personal data)
Our products are for businesses, not individuals, and so this is the most important piece of information for us. We’ll need this to provide you with an accurate quote, to provide you with a contract, and to make sure we can contact you regarding the products or services you express an interest in. If you don’t complete your application online, we’ll try to reach you to see if you need any further help, and we’ll offer you the opportunity not to be contacted again.
Information regarding the industry or sector in which your business operates
(depending on the size of the business, this may not be personal data)
We will use information regarding the sector your business operates in to help us understand your business and the way it operates and evaluate your application, as well as to ensure that we offer our products and services responsibly. We may also use this information to ensure we offer you the most appropriate pricing for your business. We may also use this information for the purposes of learning for the evaluation of other applications in future.
Details about your business’ financial revenues.
(depending on the size of the business, this may not be personal data)
Performance of a contract with the data subject (if you are an individual), or legitimate interest (if you are a business)
We’ll use your revenue to help, evaluate your application, and to decide on the right amount or pricing that we should offer to you. We may also use this information for the purposes of learning for the evaluation of other applications in future.
If we enter into a contract with you and/or your business for one of our products, we may need this information to perform that contract.
Personal information of directors/shareholders/Persons of Significant Control of your Limited company or, in the case of sole traders and partnerships, the proprietor(s) of your business:
Date of birth
We’ll use this information to undertake checks for the purposes of evaluating your application, preventing fraud and money laundering, and to verify the identity of your business’ directors before we provide any products or services to your business. We may also use this information for the purposes of learning for the evaluation of other applications in future.
If you provide us with personal information relating to a third party, you must notify them about this and direct them to read this Privacy Notice.
We’ll also use the address you’ve provided to us to contact you via post for any matters relating to an application for our products in respect of the business or for the performance of the resulting contract that we enter into with you and/or your business. We may write to you in future with offers for similar products provided by us.
We’ll ask you for your email address so that we may provide you with a link to electronically sign your contract with us. We may also use your email address to keep you updated regarding the status of your application and/or contract. If you do not complete your application having provided us with your email address, we may contact you to try and assist you with completing the application process and also to send you monthly statements should you take out one of our products.
Business phone number
We’ll use the phone number that you provide to contact you regarding your application, and if you do not complete your application having provided us with your phone number we may contact you to try and assist you with completing the application process.
We may use your phone number to contact you about the performance of any contracts that we enter into with you or your business.
Intended use of funds
We need to record and assess your intended use of funds for the purposes of preventing fraud, money laundering and crime. We may also use details regarding your intended use of funds to aid in evaluating your application. We may also use this information for the purposes of learning for the evaluation of other applications in future.
Bank account details
Performance of a contract with the data subject (if you are an individual), or legitimate interest (if you are a business)
We will need your bank account details in order to provide you with funds. We may also ask you for additional documentation regarding your bank account so that we can verify your ownership of the account, and to verify your identity.
We may ask you for copies of bank statements during your application process to help us verify your business’ revenues, and to evaluate your application. We may also use this information for the purposes of learning for the evaluation of other applications in future.
Open Banking authorisation
We may ask you for an electronic authorisation to connect to your bank and retrieve information using Open Banking. We will use this information during your application process to help us verify your business’ revenues and to evaluate your application.
We may request that you provide us with an up to date statement of your VAT returns. We will use this information to help us evaluate your application. We may also use this information for the purposes of learning for the evaluation of other applications in future.
Publicly Accessible Information
We may review information regarding your business and its directors that is freely available in the public domain; for example, media coverage, your public website and business social media accounts, and any industry specific review or registration information. We will use this information to help us evaluate your application and for verifying your identity. We may also use this information for the purposes of learning for the evaluation of other applications in future.
Whilst we have made every endeavour to provide an explicit list of all the data that we will collect, depending on the circumstances of your business we may from time to time request additional information from you during our processing of your application that are unique to your circumstances. Should we require additional information from you, we will inform you of the type and purpose of this at the time.
Suppliers: name and business contact details (email address, phone number)
We may use this information in order to evaluate your application. We may also use this information for the purposes of learning for the evaluation of other applications in future.
Data we collect indirectly or from third parties
We collect a variety of data about you from third parties. This includes the data listed below and may include other data that we notify you about from time to time.
Categories of Data
Categories of Data
Source of Data
Purpose of Processing
Credit history. Identity details.
Regulated credit bureaux, such as Equifax or Experian
We use this information to understand whether our products are suitable for you and your business, to evaluate your application, and to verify the identities of your business’ directors. We may also use this information for the purposes of learning for the evaluation of other applications in future.
In both cases relating to you, your business, and its directors
Financial transaction details that have been processed through your card terminal from your processor
Your payment processor
We use this to verify the affordability of our products for you or your business, to evaluate your application and decide on the right price to offer you, and to provide you with an estimate of the duration of repayments. We may also use this information for the purposes of learning for the evaluation of other applications in future.
If contract with us for one of our products, we will use this information to perform the contract.
Fraud prevention agencies
We will use this for the prevention of fraud and money laundering. We may also use this information for the purposes of learning for the evaluation of other applications in future.
Company registration information, and published accounts
We will use this to verify that your business is correctly registered, and to help with our underwriting checks by reviewing your published accounts. This information is part of a public record. We may also use this information for the purposes of learning for the evaluation of other applications in future.
Technical information regarding your device
The device that you use to access our website
We will collect technical information during your visit to this website to help us detect and resolve problems on our website. This information includes such information as your IP address, browser (including its version), and the type of device that you are using.
Previous or existing business landlords
We will use these references to verify that you and your business do not have outstanding liabilities or other concerns that would affect your eligibility for our products. We may also use this information for the purposes of learning for the evaluation of other applications in future.
Land Registration Details
We will use this information to help identify your, and your business’, current assets when reviewing your eligibility for our products. This information is part of a public record. This applies to England, Wales and Scotland.
Other publicly available information
Various websites (e.g. search engines, rating sites)
We will use this information to help make informed decisions when reviewing your eligibility for our products. We may also use this information for the purposes of learning for the evaluation of other applications in future.
Sharing data with third parties
In the process of providing you with a quote, in reviewing your application for one of our products, and in performing the contracts that we enter into with you, we may share your data with third parties. Details of these third parties are below. We will only share data with third parties where it is lawful for us to do so.
We may share your details with Credit Reference Agencies if you apply for one of our products. This data will be used in accordance with the Small and Medium Sized Business (Credit Information) Regulations 2015 and Small Business Enterprise and Employment Act 2015. Should you require further information regarding the use of data by Credit Reference Agencies in the UK, they have provided a shared document regarding their use of personal data – you can find it here: https://www.equifax.co.uk/crain.html.
We share your data with the British Business Bank (a UK government entity that provides us with debt funding) for their monitoring purposes
We may share details of any breach of the terms of your agreement with us with credit reference agencies. In the case of a limited liability entity, we may report the directors and/ or shareholders and/or guarantors of such entity with credit reference agencies concerning any breach of the terms of your agreement with us.
We share your data with Facebook so that we can create custom audiences for advertising campaigns. Facebook also process your data to measure the performance of advertising campaigns
We use Sagepay and Go Cardless to store and process payment details only
In the event of payment default, we may send your details to Azzurro (UK) who will represent us in collecting any outstanding debts.
We hold customer data on the Salesforce Cloud platform. Salesforce do not use or look at your data, but their servers do hold the data.
We hold customer data on the Microsoft Azure Cloud platform. Microsoft do not use or look at your data, but their servers do hold the data.
We will share your information with Fraud Prevention agencies, and we (or they) may also allow law enforcement agencies to access and use this personal data to detect, investigate, and prevent crime.
If your details were provided to us by a third party (such as a financial broker, or via a referral website) then we may provide updates regarding the status of your application back to them.
If our business (or the majority of our company assets) is acquired by another party, your information will be part of the transfer of assets.
If we sell or buy any business or assets, we may share your data with the prospective buyer or seller.
Where we engage with third parties for the purposes of raising investment, we may provide data on a strictly need-to-know basis for due diligence purposes.
We share your business name and contact details with other organisations that may offer you services of interest to you – but only if you explicitly provide us with permission to do so.
We may share your data with other Liberis group companies for the purposes of managing your account.
We may share your data with any back-up servicer in the event that we are required by our funders to transfer management of our business and operations to them
We also disclose your data in the following circumstances:
We work with various third-party service providers:
We share your information with payment processors that process financial transactions on your behalf.
We use cloud computing providers to store your data, and to help us process your application efficiently.
We may use third parties (e.g. mailing houses) to send you marketing or account information on our behalf. To do this we would need to provide them with your name and address or email address at a minimum.
We use a third-party help and support system to help us respond to your questions quickly when you’re using our website, your data are shared here only when you request assistance.
We may use third party contact centres to help us contact you by phone, and we would need to pass your information to them to enable them to reach you. They will additionally record the information that you provide to them and pass it back to us.
We may use third party operational fulfilment centres to process some parts of your application.
We use cloud based electronic signature providers during our application process, we will provide all details required to produce your contract to these providers in order to provide you with this service.
We use a service provider who provides multi-touch attribution reporting and other services for us. This third party may have access to, or process Personal Data or Client Data as part of providing those services for us.
We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.
Information outside of the EEA
Liberis is an international company with operations in and outside of the EU and EEA and we use service providers in locations based outside of the EEA. If we transfer your information to a service provider in one of these locations, we will take steps to ensure your data and rights are protected through methods approved within the relevant Data Privacy laws. Please contact us if you would like further information about how we protect your information, please contact us at firstname.lastname@example.org
Non-Personally Identifiable Information
We may make non-personally identifiable information available to third parties for various purposes. This data maybe automatically collected and would be analysed to create an aggregated view of the data, ensure the reported information was anonymous.
We may also disclose information to third parties if you consent to us doing so.
Retention of your data
We’ll keep your data only for as long as we need to – that time period may be different in different circumstances. Here are our most common scenarios:
We’ll keep records of any financial transactions, and details regarding the information that you provided to us while making an application for one of our products, for a minimum of 6 years from the end of our relationship with you. We need to do this so that we can respond to any complaints or disputes.
We’ll keep the information that’s needed to provide you with the service that you’ve requested for as long as it takes us to provide the services and for 7 years from termination of the contract for provision of the services.
If you’ve asked us not to use your details for marketing purposes, we will need to keep some details to make sure our systems and processes reflect your preferences. We will implement your opt-out request as quickly as possible. However, you may receive emails for up to 30 days, or marketing by post for up to 60 days, following your opt-out request. This is because our marketing campaigns are usually prepared about a month in advance, and it is often not feasible to remove an individual’s details after this point.
In addition, we will retain any data about you which we need in order to comply with our legal obligations (for example applicable UK tax law).
Consequences of processing
Should you choose not to provide us with your personal data, we will not be able to assess your eligibility for one of our products, and we will be unable to enter into a contract with you.
If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested, or we may stop providing existing services to you.
A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us – you’ll find all of our details in the “Contacting us” section of this notice.
access to your personal data and to certain other supplementary information that this Policy is already designed to address
require Us to correct any mistakes in your information which We hold
require the erasure of personal data concerning you in certain situations
receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
object at any time to processing of personal data concerning you for direct marketing
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
object in certain other situations to our continued processing of your personal data
otherwise restrict our processing of your personal data in certain circumstances
where consent is our lawful basis for processing your personal data, withdraw such consent
claim compensation for damages caused by our breach of any data protection laws.
As part of the processing of your personal data, decisions may be made by automated means.
We may automatically decide that you pose a fraud or money laundering risk or if our processing reveals your behaviour to be consistent with that of known fraudsters or money launderers; or is inconsistent with your previous submissions; or you appear to have deliberately hidden your true identity.
We make automated decisions based on the information that you provide, and that we gather from third parties, as part of your application to determine your financial profile. We may use automated decisions to provide you with a price reflecting your profile. The outcome of these automated decisions may mean that we do not approve your application for one of our products, or that our pricing is adjusted based on the information we have.
These automated decisions use a statistical process based on your historical transactions (details you have provided) and historical credit performance as a business and as an owner of a business (details you have provided and/or publicly available information). If you are an existing customer, the automated decisions will also take into account your performance of previous/current contractual obligations.
You have the right to request manual decision making in place of automated decision masking however this may mean we are unable to offer you are products. If you would like more information in relation to automated decision making: if you want to know more please contact us at email@example.com.
International data transfers
Whenever we, or anyone we share your data with, transfer your personal data outside of the United Kingdom or European Economic Area, we impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. We may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.
The security of your information is important to us and we will do our best to protect your data.
Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk.
Once you provide the information to us, we store this information on our secure servers, and we have implemented reasonable administrative, technical, and physical security measures to protect against the unauthorised access, destruction or alteration of your information based on its sensitivity.
Our products are not for children and to qualify, you must be over eighteen (18) years of age. You must make sure the details provided by you on registration or at any time are correct and complete. You must inform us immediately of any changes to the information that you provided when registering by updating your personal details.
Changes to this privacy notice
We may amend this notice from time to time; should amendments be made they will be posted to our website. This privacy notice was last updated 18/05/2020.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.
Should you wish to contact us with any questions or concerns you may have regarding our privacy notice, to request any amendments to the data we hold about you, or to exercise any of your other rights listed in this notice, you can contact our Data Protection Officer using any of the following methods: