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.
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.
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.
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.
3.2 Reasons we can use your personal information:
For everyday business purposes:
To enhance your experience on our website by
For marketing purposes:
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.
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:
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.
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.
8.1 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.
California Consumer Privacy Act (“CCPA”)
This California Privacy Notice is for California Residents only and supplements our online Privacy Notice. This notice describes:
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:
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:
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:
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).
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:
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:
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:
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:
To submit a request, we must verify your identity:
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.
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
Scale Space Building, 1st Floor
58 Wood Lane
London W12 7RZ