Privacy Policy

LIQD, a privately operated website based in Lithuania (“LIQD”) are committed to being fully compliant with all applicable EU data protection legislation in respect of personal data, as well to safeguarding the rights and freedoms of persons whose information the Company collects pursuant to the General Data Protection Regulation as applied to Lithuania (“GDPR”).

LIQD is the Controller of all personal data used in our business for our own commercial purposes. By registering to create a LIQD account through LIQD.co or any other mobile applications or API (“Site”), you agree that you have read, acknowledged, understood and have agreed to all of the Terms within this Privacy Policy. In this Privacy Policy, the terms “LIQD”, “we”, “us”, or “our” refers to the company LIQD Ltd. Depending upon context, “LIQD” may also refer to the Services, products, Site, content or other materials provided by LIQD.

The service operated by LIQD allows users to send, receive and to store Digital Currency (“Services”). LIQD also provides Exchange services through which users can transact with GBP and Euros to buy and sell Digital Currency with LIQD.

What is the purpose of this document?

We are responsible for deciding how we hold and use personal information about you. We are required under GDPR to notify you of the information contained in this Privacy Policy. We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Policy describes our policies and practices regarding our collection and use of your personal data, and sets forth your privacy rights. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Policy as we undertake new personal data practices or adopt new privacy policies.

Interpretation

All terms in this Privacy Policy are to be strictly defined and interpreted in accordance British English language.

Amendments

LIQD reserves the right to modify and amend this Privacy Policy. We will make reasonable efforts to ensure that in the event of any significant changes this Privacy Policy, you will be notified and given advanced notice by an appropriate method (for example, by email to the address you provide to us during registration for a user account, or via notice on the Site). However, it remains your responsibility to check this Privacy Policy from time to time to ensure that you still agree with it, your continued use of the Site will be deemed to be your acceptance of any changes we make. If you do not agree with any such amendment, your only exercisable remedy is to terminate your account. Your continued use of the Site will constitute acceptance of the Privacy Policy. By agreeing to this Privacy Policy, you understand and agree that LIQD will not be liable to you or any such third party for any alteration or conclusion of any such LIQD Services as a result of an amendment to this Privacy Policy.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

• Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).
• Collected only for specified, explicit and legitimate purposes (Purpose Limitation).
• Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation).
• Accurate and where necessary kept up to date (Accuracy).
• Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation).
• Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Integrity and Confidentiality).

1. What Personal Information LIQD may Collect.

1. Upon registration of your LIQD account, to allow us to provide the Services sought by you, we may collect the following personal information;

1. Your legal name;
2. Your photographic identification, including a high-quality image of your government issued identity; passport, national identity card, and driving licence;
3. Your current residential address;
4. Your e-mail address;
5. Your banking details including account numbers;
6. Your date of birth;
7. Your occupation and;
8. An acceptable document confirming your current residential address and billing address if different.

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you or we may be prevented from complying with our legal obligations (such as our Anti-money laundering and countering the financing of terrorism obligations). This may result in us suspending, deactivating and/or cancelling your LIQD account in accordance with our terms of use. Your photographic identification would be considered “Special Category Data” and requires higher levels of protection. We are required to have further justification for collecting, storing and using this type of personal information. We have in place appropriate safeguards which we are required by law to maintain when processing such data. We process this special category of personal information to carry out our legal obligations, for us and for you to exercise rights in connection with your contract with us and to mitigate the risks to you of identity theft. By providing us with your photographic identification, you consent to us using it for the purposes set out in this privacy policy. Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests), where you are not capable of giving your consent, or where you have already made the information public.

1. 2. Through your use of LIQD Services we have access to and may collect information regarding, but not restricted to;

1. 2. 1. Your internet browser;
      2. The type of device you use to access our Services;
      3. Your Internet Protocol address (IP address);
      4. Your location and;
      5. Your communications with LIQD and any such employee, or agents.

1. 3. As part of the registration process automated decision-making takes place. We use electronic systems to make a decision without human intervention in respect of assessing whether you match the eligibility criteria as set out in our Terms of Use to open an account with us. We use automated decision-making as it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.

2. Use of Personal Information.

We will only use your personal information as the law allows us to. Your personal data will be used to;

2. 1. Personalise your experience and to better respond to your individual needs;
   2. To improve our Site;
   3. To analyse use of our Site;
   4. To provide and improve customer service;
   5. To undertake verification procedures pursuant to our legal obligations and internal policies;
   6. To process transactions;
   7. To send periodic emails. The email address you provide for order processing may be used to send you information and updates pertaining to your order or request, as well as receiving occasional company news, updates, promotions, related product or service information, etc;
   8. To administer a contest, promotion, survey or other Site feature.
   9. Business Management and planning, including accounting and auditing.
   10. Conducting business reviews, business performance and determining business requirements.
   11. Dealing with legal disputes involving you.
   12. To prevent fraud.
   13. To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution; and
   14. To conduct data analytics studies to review and better understand client retention.

We will only process your Personal Information for the purpose(s) for which it has been provided to us unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

3. Transferring information outside Lithuania

3. 1. We will only transfer the personal information we collect about you in order to perform our contract with you.
   2. The countries to which we transfer your data are either in the EEA or are deemed to provide an adequate level of protection for your personal information.

4. Third Parties.

4. 1. Your information, whether public or private, will not be sold, exchanged, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or Service requested by the customer or, for complying our legal obligations and internal policies.

5. Non – Personal Information.

5. 1. Non – Personal Information refers to information that we may gather that will not relate to you as an individual data subject. We may use any such general data such as the times you view or use our services for analytical and/or statistical purposes.
   2. Any such Non- Personal Information may be used to improve the Site and the delivery of any Services we provide.

6. Personal Information and Security.

6. 1. LIQD uses a strict code of practice when handling encryption and security. We use Secure Sockets Layered (SSL) and ensure only trusted LIQD staff see the data they need to and no more.
   2. We have implemented security measures to ensure the confidentiality of your Personal Information and to protect your Personal Information from loss, misuse, alteration or destruction.
   3. We implement a variety of security measures to maintain the safety of your Personal Information when you submit a request, place an order or access your Personal Information. These security measures include: password protected directories and databases to safeguard your information, SSL technology to ensure that your information is fully encrypted and sent across the Internet securely or Payment Card Industry Data Security Standard (PCI) Scanning to actively protect our servers from hackers and other vulnerabilities. We offer the use of a secure server. All supplied sensitive/credit information is transmitted via SSL technology and then encrypted into our Database to be only accessed by those authorised with special access rights to our systems, and are required to keep the information confidential.
   4. Only authorised personnel of LIQD have access to your Personal Information, and these personnel are required to treat the information as confidential. The security measures in place will, from time to time, be reviewed in line with legal and technical developments.

7. Rights of access, correction, erasure, and restriction

7. 1. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
   2. You can update your Personal Information at any time in Settings. To update any Personal Information which is not editable please contact us
   3. Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

7. 3. 1. Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
      2. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
      3. Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
      4. Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
      5. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
      6. Request the transfer of your personal information to another party.
      7. Request a decision arrived at by automated means be reviewed by a Member of our staff, for an opportunity to put your views forward and to be able to contest that decision, with a view to that decision, if felt appropriate, be overturned.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us.

7. 4. No fee usually required You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
   5. What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

8. Cookie Policy.

8. 1. LIQD uses cookies to enhance your experience on our Site. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website.
   2. Cookies are typically stored on your computer’s hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our Site, analyse trends, and administer the Platform. The information collected from cookies allows us to determine such things as which parts of our Site are most visited and difficulties our visitors may experience in accessing our Site. With this knowledge, we can improve the quality of your experience on the Platform by recognising and delivering more of the most desired features and information, as well as by resolving access difficulties.
   3. We use third party service provider(s), to assist us in better understanding the use of our Site. Our service provider(s) will place cookies on the hard drive of your computer and will receive information that we select that will educate us on such things as how visitors navigate around our site, what products are browsed, and general Transaction information. Our service provider(s) analyses this information and provides us with aggregate reports. The information and analysis provided by our service provider(s) will be used to assist us in better understanding our visitors’ interests in our Site and how to better serve those interests. The information collected by our service provider(s) may be linked to and combined with information that we collect about you while you are using the Platform.
   4. By using our Site, you are agreeing that we may use cookies for the purposes set out above.