US Privacy Policy

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.

Liberis Online Privacy Policy

Liberis, Inc. takes your privacy seriously. This Online Privacy Policy explains how the Company gathers and processes your personal information in compliance with the relevant data protection regulations, laws and guidance. Together with our Website Terms and Conditions, this policy provides you with important information regarding your rights and obligations, and explains how, why and when we collect and process your personal data. Please read this Online Privacy Policy carefully before using our website or registering to use our products or services. By visiting www.liberisgroup.com you are accepting and consenting to the practices described in this Online Privacy Policy.

References in this Online Privacy Policy and on our website to “we,” “our” or “us” are references to Liberis. References to “you” and “your” mean each natural or legal person who uses our website or the associated products or services and also includes the owners, executive officers, senior managers and general partners of any business that requests or receives products or services from Liberis, and any other individuals who perform similar functions (the “Principals”). References to the “business” mean the individual, corporation, association, partnership, limited liability company, estate, trust, or any other entity that applies for or obtains products and services from Liberis.

What Information Do We Collect?

Liberis processes your personal information to meet our legal, statutory, and contractual obligations and to provide you with our products and services and to send you marketing messages. We will never intentionally collect any unnecessary personal data from you and do not process your information other than as specified in this Online Privacy Policy.

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:

Name
Percentage of ownership in the business
Home street address
Telephone number
Email address
Social security number
Date of birth
Bank account and Open Banking data

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.

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.

How We Use Your Personal Information

3.1 Liberis takes your privacy very seriously and will disclose and use your personal information only as described in this Online Privacy Policy. You are free to opt-out of receiving email offers at any time at any time by emailing dataprotection@liberis.co.uk or by clicking the unsubscribe link in any marketing email you receive from us. This will not unsubscribe you from critical emails required for the provision of products and services to which you have subscribed. This includes but is not limited to emails regarding payments due, payments received and payments missed. You may opt-out of future text solicitations by responding to any text with the word “STOP” and may opt-out of telephone solicitations to your residential or mobile phone by asking the caller to be placed on our do-not-call list.

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.

Cookies and Similar Technologies

5.1 Our website may use cookies to store information about your site usage. A cookie is a small text file that is sent to your browser from a web server and then stored on your hard drive. Cookies enable us to recognize your computer and record information from your visits to the site, such as your preferred settings. This saves you having to re-enter the same data each time you use the site and allows us to provide you with a more customized experience.

5.2 We may also use cookies and analytical software to collect anonymous data for internal research purposes, including without limitation:

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.

5.4 Currently our website does not respond differently or limit practices under the terms of this Online Privacy Policy when you access our online services with a browser that uses a do not track signal or similar mechanism.

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.

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.

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.

Changes to this Online Privacy Policy

9.1 We may amend or update this Online Privacy Policy periodically to reflect the changes in our business and practices. The revised policy will be posted on our website. Any changes will become effective immediately upon posting to our website.

For questions, contact us at dataprotection@liberis.co.uk ,or call us at +1(844) 754-2370

Your California Privacy Rights

California Consumer Privacy Act (“CCPA”)

Privacy Notice

This California Privacy Notice is for California Residents only and supplements our online Privacy Notice. This notice describes:

The Personal Information that Liberis (together the “Company,” “we,” “our,” or “us”) collects in the course of its business and explains how this information is collected, used, sold, disclosed, shared, and retained;
The rights provided by the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”) to California Residents (“consumer” or “you”) regarding their Personal Information; and
How consumers can exercise those rights.

Your Personal Information

What is Personal Information?

We may collect, use, or disclose your Personal Information. Personal Information is information that identifies, relates to, describes, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with you (“Personal Information”). It can also include other pieces of information which can be used to identify you, either directly or indirectly, such as a cookie. Personal Information does not include: (1) publicly available information, such as information that is lawfully made available from federal, state, or local records, or (2) de-identified or aggregate consumer information.

What types of Personal Information do we collect and use?

The CCPA requires us to disclose certain information regarding our collection, use, sale, sharing, disclosing, and retention of your Personal Information in the course of providing our financial services to you. In the past twelve (12) months, we have collected the following categories of Personal Information for business or commercial purposes:

Identifiers (e.g., passport, driver’s license, social security number, taxpayer identification number, email address, real name, alias, internet protocol address, or other similar identifiers, address, telephone number, and other contact information);
Personal information described in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)) (e.g., name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information);

Characteristics of a protected class (e.g., nationality, race, etc.);
Commercial records (e.g., contractual/contact information (i.e., our ‘history’ together – services provided or discussed, payment information (e.g., bank account or wiring instructions));

Internet or other electronic network activity (e.g., browsing history, search history, information regarding your interaction with our website, cookies);
Geolocation data;
Audio, electronic, visual and similar information (e.g., call and video recordings);

Professional or Employment information (e.g., job title, company name, address, telephone number, employment history, type of entity, Employer Identification Number, date business started, financial information including account and routing numbers and management and/or audited accounts);

Inferences drawn from other personal information (for example, data, assumptions, or conclusions derived from facts, evidence, or another source of information or data reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes); and
Sensitive Personal Information (e.g., social security number, driver’s license number, passport number, account number, precise geolocation, racial or ethnic origin, etc.).

Where do we collect your Personal Information from?

Typically, we will collect information from you when you contact us directly or provide information to us to provide you with our products and services. In addition, we collect information from and about you in the following ways:

You (or your representative)
Data Analytics Providers
Marketing Partners
Our website and mobile applications
Third-party websites
Services Providers
Credit Reporting Agencies
Government Agencies
Third parties (such as your card processor, brokers or our partners) who refer you to us for our products and Services.
Publicly accessible databases

We will only use your Personal Information for the reasons for which we collected it. 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.

What do we do with your Personal Information?

We may use your Personal Information for one or more of the following business or commercial purposes:

To provide you with our products and associated services: We use personal information to assess your eligibility for our funding products, offer and provide our funding products and associated services, including: (1) establishing, maintaining, supporting, and servicing your product; (2) providing services, products, or information you may have requested from us; and (3) performing services such as maintaining or servicing your MyLiberis accounts, providing customer service, verifying customer information, providing financing, searching CRA or other database records, providing analytic services, or providing similar services on our own behalf or on the service provider’s behalf.
Security and Fraud Detection: We use personal information for our security and fraud detection services including: detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.
Debugging: We use personal information to engage in debugging to identify and repair errors that impair existing intended functionality.
Improvement of Products and Services: We use personal information to verify, maintain, and improve our products and services.
Internal Research: We use personal information for our internal research related to technological development and demonstration.
Advertising and Marketing Services: We use personal information to provide advertising or marketing services on our own behalf.
Audits: We use personal information to audit current interactions with you and related transactions (e.g., counting and verifying ad impressions, auditing compliance).
Merger/Acquisition/Bankruptcy, etc.: We may use your personal information as part of a merger, acquisition, bankruptcy, other transaction where a third party assumes control of us, or where such information is requested by our lenders.
Commercial/Economic Interests: We use personal information to advance our commercial or economic interest.
Legal Obligations: We use personal information to comply with legal obligations, including enforcing our Terms and Conditions.
Aggregated information: 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.

Who do we disclose your Personal Information with?

We may disclose your personal information to employees, service providers, or contractors in order to carry out specific business or commercial purposes. In the preceding 12 months, we have disclosed the following categories of consumer personal information for business or commercial purposes to service providers and the following categories of third parties:

Identifiers: We share this information with Third party firms which provide background checks for due diligence and anti-money laundering and External legal counsel, and consultants (including regulatory and tax).

Personal information described in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)): We share this information with Third party firms which provide background checks for due diligence and anti-money laundering and External legal counsel, and consultants (including regulatory and tax).

Commercial records: We share this information with Third party firms which provide background checks for due diligence and anti-money laundering and External legal counsel, and consultants (including regulatory and tax).
Audio, electronic, visual and similar information: We share this information with Third party firms which provide background checks for due diligence and anti-money laundering and External legal counsel, and consultants (including regulatory and tax).

We do not and will not sell or share (for cross-contextual behavioral advertising) your Personal Information to any third party, nor have we done so in the preceding 12 months. Similarly, we do not and will not collect, sell, or share (for cross-contextual behavioral advertising) the Personal Information of minors under 16 years of age.

How will we use your sensitive Personal Information?

We only collect or use sensitive Personal Information for the following business or commercial purposes:

To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted Personal Information.
To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.
For short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business.
To perform services on behalf of the business.
To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the business.
To collect or process sensitive Personal Information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

How Long We Retain Your Personal Information

We store 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.

Your Rights under the CCPA

The CCPA provides you with certain rights regarding the collection, use, and disclosure of your Personal Information. As described in more detail below, the CCPA provides you with the following rights:

The Right to Know/Access what Personal Information we have collected about you. Before or when we collect your Personal Information, you have the right to know:

The categories of Personal Information (including Sensitive Personal Information) we collect, the business or commercial purpose for which we collect and use the Personal Information, and whether we sell or share that information; and
How long we intend to keep each category of Personal Information, including Sensitive Personal Information.

You also have the right to request that we provide you with certain information about the Personal Information we collect, use, share, disclose, or sell, as well as the categories and specific pieces of information that we have collected about you. Specifically, you have the right to request the following information:

The categories of Personal Information we collect.
The categories of sources from which the Personal Information is collected.
The business or commercial purpose for collecting, selling, or sharing Personal Information.
The categories of third parties to whom we disclose Personal Information.
If we disclosed your Personal Information for a business purpose, the categories of Personal Information that we disclosed about you and the categories of third parties to which we disclosed that Personal Information for a business purpose.
The specific pieces of Personal Information the business has collected about you.

The Right to Delete the Personal Information we collected and maintained about you once we verify your request. However, there may be reasons we need to keep your Personal Information and we will inform you if that is the case.
The Right to Correct inaccurate Personal Information we have collected from you and maintained about you. Once we verify your request, including the inaccurate information, we will update your inaccurate Personal Information from our records and our service provider’s records.
The Right to Limit the Use and Disclosure of Sensitive Personal Information if we use the information for reasons that are not aligned with why we obtained such information. However, we can use this information as permitted by law, to follow the law, and to give you the best service.
The right to Non-Discrimination or Non-Retaliation, which means we cannot discriminate or retaliate against you if you exercise your rights under the CCPA.

You also have the Right to Opt-Out of the sale or sharing (for targeted advertising) your Personal Information. However, we do not sell or share your Personal Information.

Submitting a Verifiable Request to Know, Correct, or Delete Personal Information

To exercise your Right to Know, Correct, or Delete your Personal Information, please submit a request to us by:

Email: dataprotection@liberis.co.uk
Mail: Data Protection Officer, Liberis Ltd., Scale Space Building, 1^st Floor, 58 Wood Lane, London, W12 7RZ

To submit a request, we must verify your identity:

Password-Protected Accounts: If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. We will also require you to re-authenticate yourself before we disclose your Personal Information. If we suspect fraudulent or malicious activity on or from your account, we will need to perform further verification to determine whether your request is authentic, and you are the person about whom we have collected the Personal Information.
Non-Account Holders: If you do not hold a password-protected account with us, we will verify you as follows:
- If you submit a request to know the categories of Personal Information, we will ask you for at least two pieces of information, which we will match with at least two data points in our system to verify your identity.

- If you submit a request to know specific pieces of Personal Information, we will ask you for at least three pieces of information, which we will match with at least three data points in our system to verify your identity. You will also be required to submit a signed declaration under penalty of perjury stating that the requestor is the consumer whose Personal Information is the subject of the request. Please note there is certain information we are not permitted to provide you, such as certain Sensitive Personal Information.

We will generally avoid requesting additional information from you to verify you unless necessary. This information will only be used to verify your identity and will delete any new Personal Information we collect to verify your identity as soon as possible.

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, which is an individual or business registered with the Secretary of State, 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.

Please note that we will not respond to a request for your Personal Information if you have submitted more than two requests in a 12-month period.

Responding to a Request to Know, Correct, or Delete Personal Information

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 45 days unless we need more time. We will provide you with additional information if that is the case.

Changes to Our California Privacy Notice

We are required by law to update this California Privacy Notice at least once every 12 months. We will notify you when we make changes to this privacy notice. This California Privacy Notice was last updated on February 7, 2023.

Contact Information

If you have any questions regarding our privacy policies, our California Privacy Notice, the ways in which we collect, use, or disclose your Personal Information, or how to exercise your rights under the CCPA, please do not hesitate to contact us at:

Data Protection Officer

Liberis Ltd.

Scale Space Building, 1^st Floor

58 Wood Lane

London W12 7RZ

E–mail: dataprotection@liberis.co.uk

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