US Privacy Policy

  • Introduction

    • Your privacy is important to us. This privacy statement explains our collection, use, and disclosure of personal data.  This privacy statement applies to Liberis, Inc. and to our controlled affiliates and subsidiaries (“Liberis”, “we”, “our”, “us””). References to our “services” in this statement include our websites, apps, and other products and services. This statement applies to our services that display or reference this statement, but it does not apply to any services that display or reference a different privacy statement.

      References in this privacy statement and on our website 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.

  • PERSONAL DATA WE COLLECT

    • The personal data we collect depends on how you interact with us, the services you use, and the choices you make.

      We collect information about you from different sources and in various ways when you use our services, including information you provide directly, information collected automatically, information from third-party data sources, and data we infer or generate from other data.

      Information you provide directly. We collect personal data you provide to us which may relate to you or your Principals or business partners. For example:

      • Name and contact information. We collect name, signature, alias, and contact details such as email address, postal address, and phone number.
      • Demographic data. In some cases, such as when you register or participate in surveys, we request that you provide age, gender, marital status, physical characteristics or description, and similar demographic details.
      • Professional or employment-related information. We collect your job title, company name, entity type, employer identification number, contractual/contact information, and employment history.
      • Education information. We collect your education history.
      • Payment and Financial information. We collect credit and debit card numbers, financial account information, account and routing numbers, percentage of ownership in the business, open banking data, management and/or audited accounts, and other payment and bank details.
      • Content and files. We collect the photos, documents, or other files you upload to our services; and if you send us email messages or other communications, we collect and retain those communications (for example, we record calls and store the contents of your communications with us via our website, app, chat features, and other channels). 
      • Sensitive Personal Data.
        • Government ID. We collect government-issued identifiers such as driver’s license or state identification card, passport, and social security numbers.
        • Account access information. We collect information such as a username or account number in combination with a password, security or access code, or other credential that allows access to an account.

      Information we collect automatically. When you use our services, we collect some information automatically. For example:

      • Identifiers and device information. When you visit our websites, our web servers automatically log your Internet Protocol (IP) address and information about your device, including device identifiers (such as MAC address); device type; and your device’s operating system, browser, and other software including type, version, language, settings, and configuration. As further described in the “Cookies, Mobile IDs, and Similar Technologies” section below, our websites and online services store and retrieve cookie identifiers and other data.
      • Geolocation data. Depending on your device and app settings, we collect geolocation data when you use our apps or online services. This information may include precise geolocation data, meaning data derived from a device and that is used to locate you within a circle with a radius of 1,850 feet or less, which is considered a type of sensitive personal data.
      • Usage data. We automatically log your activity on our websites, apps and connected products, including the URL of the website from which you came to our sites, pages you viewed, how long you spent on a page, access times, and other details about your use of and actions on our website.

      Information we obtain from third-party sources. We also obtain the types of information described above from third parties. These third-party sources include, for example:

      • Data brokers. Data brokers and aggregators from which we obtain data to supplement the data we collect.
      • Third-party partners. Third-party applications and services, including social networks you choose to connect with or interact with through our services.
      • Co-branding/marketing partners. Partners with which we offer co-branded services or engage in joint marketing activities.
      • Service providers. Third parties that collect or provide data in connection with work they do on our behalf, for example companies that determine your device’s location based on its IP address.
      • Publicly available sources. Public sources of information such as open government databases and reports such as credit, fraud and Office of Foreign Asset Control (“OFAC”) reports.

      Information we create or generate. We infer new information from other data we collect, including using automated means to generate data, assumptions, or conclusions derived from facts, evidence, or another source of information. For example, we infer your general geographic location (such as city, state, and country) based on your IP address.

      When you are asked to provide personal data, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain services or features, those services or features may not be available or fully functional.

  • COOKIES, MOBILE IDs, AND SIMILAR TECHNOLOGIES

    • We use cookies, web beacons, and similar technologies to operate our websites and online services and to help collect data, including usage data, identifiers, and device information.

      What are cookies and similar technologies?

      Cookies are small text files placed by a website and stored by your browser on your device. A cookie can later be read when your browser connects to a web server in the same domain that placed the cookie. The text in a cookie contains a string of numbers and letters that may uniquely identify your device and can contain other information as well. This allows the web server to recognize your browser over time, each time it connects to that web server.

      Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website or email. When your browser opens a webpage or email that contains a web beacon, it automatically connects to the web server that hosts the image (typically operated by a third party). This allows that web server to log information about your device and to set and read its own cookies. In the same way, third-party content on our websites (such as embedded videos, plug-ins, or ads) results in your browser connecting to the third-party web server that hosts that content. We also include web beacons in our email messages or newsletters to tell us if you open and act on them.

      How do we and our partners use cookies and similar technologies?

      We and our analytics partners use these technologies in our websites and online services to collect personal data when you use our services, including personal data about your online activities over time and across different websites or online services. This data is used to store your preferences and settings, enable you to sign-in, analyze how our websites and apps perform, track your interaction with the site or app, develop inferences, combat fraud, and fulfill other legitimate purposes. We and/or our partners also share the data we collect or infer with third parties for these purposes. For more information about the third-party analytics partners that collect personal data on our services, please see the “Our Disclosure of Personal Data” section of this statement.

      What controls are available?

      There are a range of cookie and related controls available through browsers and elsewhere. See the “Choice and Control of Personal Data” section below for details.

  • OUR USE OF PERSONAL DATA

    • We use the personal data we collect for purposes described in this privacy statement or as otherwise disclosed to you. For example, we use personal data for the following purposes:

      Purposes of Use

    • Product and service delivery. To provide and deliver our services, including troubleshooting, security and fraud prevention and detection, and improving and personalizing those services.

    • Business operations. To operate our business, such as billing, accounting, improving our internal operations, securing our systems, detecting fraudulent or illegal activity, and meeting our legal obligations.

    • Product improvement, development, and research. To develop new services or features, and conduct research.

    • Personalization. To understand you and your preferences to enhance your experience and enjoyment using our services.

    • Customer support. To provide customer support and respond to your questions

    • Communications. To send you information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.

    • Marketing. To communicate with you about new services, offers, promotions, rewards, contests, upcoming events, and other information about our services and those of our selected partners (see the “Choice and Control” section of this statement for information about how to change your preferences for promotional communications).

  • OUR DISCLOSURE OF PERSONAL DATA

    • We disclose personal data with your consent or as we determine necessary to complete your transactions or provide the services you have requested or authorized. In addition, we disclose each of the categories of personal data described above, to the types of third parties described below, for the following business purposes:

      • Service providers. We provide personal data to vendors or agents working on our behalf for the purposes described in this statement. For example, companies we’ve hired to provide customer service support or assist in protecting and securing our systems and services may need access to personal data to provide those functions.
      • Financial services and payment processing. When you provide payment data, for example to make a purchase, we will disclose payment and transactional data to banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, analytics, or other related financial services. In the event of payment default, we may send your details to C2C and other debt purchasers and collectors or service providers who will represent us in collecting any outstanding debts.
      • Affiliates. We enable access to personal data across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access helps us to provide our services and operate our business.
      • Corporate transactions. We may disclose personal data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.
      • Legal and law enforcement. We will access, disclose, and preserve personal data when we believe doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement, national security, or other government
      • Security, safety, and protecting rights. We will disclose personal data if we believe it is necessary to:
        • protect our customers and others, for example to prevent spam or attempts to commit fraud, or to help prevent the loss of life or serious injury of anyone;
        • operate and maintain the security of our services, including to prevent or stop an attack on our computer systems or networks; or
        • protect the rights or property of ourselves or others, including enforcing our agreements, terms, and policies.

      Third party analytics companies also collect personal data through our website and apps including identifiers and device information (such as cookie IDs, device IDs, and IP address), geolocation data, usage data, and inferences based on and associated with that data, as described in the “Cookies” section of this statement and in the Cookie tool on our website. For example, we use Google Analytics on our website to help us understand how users interact with our website; you can learn how Google collects and uses information at www.google.com/policies/privacy/partners.

      Please note that some of our services also include integrations, references, or links to services provided by third parties whose privacy practices differ from ours. If you provide personal data to any of those third parties, or allow us to share personal data with them, that data is governed by their privacy statements.

      Finally, we may disclose de-identified information in accordance with applicable law.

  • CHOICE AND CONTROL OF PERSONAL DATA

    • We provide a variety of ways for you to control the personal data we hold about you, including choices about how we use that data. In some jurisdictions, these controls and choices may be enforceable as rights under applicable law.

      Access, portability, correction, and deletion. If you wish to access, copy, download, transfer, correct, or delete personal data about you that we hold, contact us at our email address or physical address detailed in the “How to Contact Us” section below. To provide, correct, or delete specific pieces of personal data we will need to verify your identity to the degree of certainty required by law:

      • Where you have a password-protected account with us: 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 data. 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 data.
      • 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 data, 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 data, 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 data is the subject of the request. Please note there is certain information we may not be permitted to provide you, such as certain sensitive personal data.

      If we are unable to verify your identity, we will let you know and explain why we were unable to verify your identity.

      Communications preferences. You can choose whether to receive promotional communications from us by email, SMS, physical mail, and telephone. If you receive promotional email or SMS messages from us and would like to stop, you can do so by following the directions in that message or by contacting us as described in the “Contact Us” section below. If you receive a sales call from us, you can ask to be placed on our do-not-call list. These choices do not apply to certain informational communications including surveys and mandatory service communications.

      Profiling and automated decision-making. Some privacy laws provide a right to opt-out from profiling and/or automated decision-making that produce a legal or similarly significant effect. We process personal data to assess fraud and money laundering risk. To opt-out from such processing, contact us in the methods described in the “How to Contact Us” section below.

      Browser or platform controls.

      • Cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our website. If you choose to delete cookies, the settings and preferences controlled by those cookies may be deleted and may need to be recreated.

      Email web beacons. Most email clients have settings that allow you to prevent the automatic downloading of images, including web beacons, and the automatic connection to the web servers that host those images.

      Except for the automated controls described above, if you send us a request to exercise your rights or these choices, to the extent permitted by applicable law, we may charge a fee or decline requests in certain cases. For example, we may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or other rights of another person, would reveal a trade secret or other confidential information, or would interfere with a legal or business obligation that requires retention or use of the data. Further, we may decline a request where we are unable to authenticate you as the person to whom the data relates, the request is unreasonable or excessive, or where otherwise permitted by applicable law. If you receive a response from us informing you that we have declined your request, in whole or in part, you may appeal that decision by submitting your appeal to our data protection officer using the contact method described at the bottom of this privacy statement.[1]

      [1] A description of how a consumer can appeal a decision regarding a request to exercise rights is required by several U.S. state privacy laws, including those in Colorado, Connecticut, Virginiaand Utah (Colo. Rev. Stat. §6-1-1306(3)(a); Conn. Gen. Stat. §42-518(d); Va. Code Ann. § 59.1-577(C); Utah Admin. Code § 13-58-204(3)(d)(ii)).

  • CALIFORNIA PRIVACY RIGHTS

    • If you are a California resident and the processing of personal data about you is subject to the California Consumer Privacy Act (CCPA), you have certain rights with respect to that information.

      Notice at Collection. At or before the time of collection, you have a right to receive notice of our practices, including the categories of personal data and sensitive personal data to be collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. You can find those details in this statement by clicking on the above links.

      Right to Know. You have a right to request that we disclose to you the personal data we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal data. Note that we have provided much of this information in this privacy statement. You may make such a “request to know” by using the contact method described at the bottom of this privacy statement .

      Rights to Request Correction or Deletion. You also have rights to request that we correct inaccurate personal data and that we delete personal data under certain circumstances, subject to a number of exceptions. To make a request to correct or delete, using the contact method described at the bottom of this privacy statement. 

      Note that we do not “sell” or “share” personal data as defined by the CCPA and have not done so in the past 12 months.

      We do not knowingly sell or share the personal data of minors under 16 years of age.

      Right to Limit Use and Disclosure of Sensitive Personal Data. You have a right to limit our use of sensitive personal data for any purposes other than to provide the services or goods you request or as otherwise permitted by law.

      Note that we do not use sensitive personal data for any such additional purposes.

      You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

      Further, to provide, correct, or delete specific pieces of personal data we will need to verify your identity to the degree of certainty required by law as described in the “Choice and Control of Personal Data” section.

      Finally, you have a right to not be discriminated against for exercising these rights set out in the CCPA. 

      Additionally, under California Civil Code section 1798.83, also known as the “Shine the Light” law, California residents who have provided personal data to a business with which the individual has established a business relationship for personal, family, or household purposes (“California Customers”) may request information about whether the business has disclosed personal data to any third parties for the third parties’ direct marketing purposes.

      We comply with this law by offering our customers a choice about the disclosure of personal data to third parties for their direct marketing purposes, and you can make or change such choice by [INSERT DESCRIPTION FOR HOW TO OPT-IN OR OPT-OUT FROM DATA SHARING FOR DIRECT MARKETING PURPOSES.

      California Customers may request further information about our compliance with this law by emailing dataprotection@liberis.co.uk. Please note that businesses are required to respond to one request per California Customer each year and may not be required to respond to requests made by means other than through the designated email address.

  • RETENTION OF PERSONAL DATA

    • We retain personal data for as long as necessary to provide the services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and for other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations.

  • LOCATION OF PERSONAL DATA

    • The personal data we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers process data, some of which may have laws that offer different levels of data protection than the country in which you reside. The storage location(s) are chosen to operate efficiently and improve performance. We take steps to process and protect personal data as described in this statement wherever the data is located.

  • SECURITY OF PERSONAL DATA

    • We take reasonable and appropriate steps to help protect personal data from unauthorized access, use, disclosure, alteration, and destruction.

      To help us protect personal data, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts.

  • CHANGES TO THIS PRIVACY STATEMENT

    • We will update this privacy statement when necessary to reflect changes in our services, how we use personal data, or the applicable law. When we post changes to the statement, we will revise the "Last Updated" date at the top of the statement. If we make material changes to the statement, we will provide notice or obtain consent regarding such changes as may be required by law.

  • HOW TO CONTACT US

    • If you have a privacy concern, complaint, or a question for Liberis or our data protection officer, please contact us at dataprotection@liberis.com

      Our address is:

      Liberis Ltd.

      Scale Space Building, 1st Floor

      58 Wood Lane

      London W12 7RZ

      Telephone:  +1(844) 754-2370.

Last Updated: 16 April 2025