Liberis, Inc. (“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 is Personal Information?
Personal information is information about an identifiable individual. This includes information that identifies, relates to, describes, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with you. It can also include other pieces of information which can be used to identify you, either directly or indirectly, such as a cookie or an IP address. Personal information also includes publicly available personal information, although your consent is not required to collect, use or disclose publicly available personal information in certain circumstances.
2. What Information Do We Collect?
2,2 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:
We may also require written authorization from each Principal to obtain consumer credit reports about them.
2.3 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; business number (assigned by Canada Revenue Agency); 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 Financial Transactions and Reports Analysis Centre (“FINTRAC”) reports on each Principal.
We may require confirmation that the business is continuing to take payments through the card terminal(s) provided to us.
3. How we collect information
3.1 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 through credit reports obtained from a consumer reporting agency (“CRA”) or from other information databases such as fraud and FINTRAC reporting sources.
Specifically, we collect information from and about you in the following ways:
If we need to use your personal information for another purpose, we will tell you about it, explain the legal basis which allows us to do so, and obtain your explicit consent.
4. How We Use Your personal information
4.2 Reasons we can use your personal information:
4.3 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.
7. Information Security
7.1 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:
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.
7.2 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.
7.3 We retain personal information for as long as we believe is reasonably necessary or appropriate to fulfil our business or commercial purposes or to comply with applicable law, audit requirements, regulatory requests, or orders from competent courts.
8. Protecting Children’s Privacy Online
Liberis’ website is not directed to individuals under the age of majority. We request that individuals under the age of majority 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 the age of majority without obtaining written, verifiable consent from a parent or legal guardian.
9. Using other websites
9.1 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.
9.2 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.
9.3 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.
9.4 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.
10. Your rights
10.1 Under Canadian law, you have the following rights in relation to your personal information:
To exercise any of these rights, please contact our Data Protection Officer through one of the methods of contact listed below.
10.2 Before we provide you with access to your personal information, we must first verify your identity:
If we are unable to verify your identity, we will let you know and explain why we were unable to verify your identity.
If you would like to use an authorized agent to submit a verifiable request, you must provide the authorized agent with written permission to do so and verify your own identity directly with us or directly confirm that you provided the authorized agent with permission to submit the request. We may deny a request from an agent that does not submit proof that they are authorized to act on your behalf.
Once we receive your request, we will send you an acknowledgment email within 10 days and provide you with next steps for processing your request, including verifying your identity. We will respond to your request within 30 days of receipt unless we need more time. We will provide you with additional information if that is the case.
11.2 For questions or to access your personal information, you may contact our Data Protection Officer in the following ways:
Telephone: 011 44 (844) 754-2370,
Mail: Data Protection Officer, Liberis Inc., Industrious, 675 Ponce de Leon Ave, NE Suite 7500, 8500 & NE223, Atlanta, GA 30308.