LIQUIDUS HUB Privacy Policy

LIQUIDUS HUB Privacy Policy

This Site, images, Products and Services are Copyright ©2022 LIQUIDUS and LIQ collectively“LIQUIDUS”. All rights reserved.

Last updated: 20 January 2022


1. Introduction
2. PI LIQUIDUS may collect about you
3. LIQUIDUS may collect PI in relation to you
4. Purpose and legal basis for processing your personal information (PI)
5. To whom LIQUIDUS disclose your PI
6. Marketing and exercising your right to opt-out of marketing
7. Third-party marketing/sale of PI
8. PI retention
9. PI security
10. Your rights
11. Contacting LIQUIDUS
12. Linked websites
13. Change to this Privacy Policy

LIQUIDUS requests you to take time to carefully read through this information. The information contained
within this Privacy Policy is applicable to any person or entity who accesses, uses, relies on, interacts or
engages with our Site, Products and Services.

1. Introduction

If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our Site, Products
and Services immediately. This Privacy Policy applies to all information collected through our Site, Products and
Services, as well as any related services, sales, marketing, products and events. Please also read our Website Terms
of Use (“Terms”) which govern all LIQUIDUS web pages (“Site”).
LIQUIDUS are committed to safeguarding your Personal Information (“PI”), your right to privacy and where applicable
processing PI in line with applicable privacy and data protection laws as applicable in each jurisdiction we operate in.
LIQUIDUS may use third-party providers to collect and process information, including financial information (for
example relating to debit and credit card details to process payments via a third-party) to provide the Site, Products
and Services to you. If you have any questions or concerns about this Privacy Policy, or our practices with regards to
your personal information, please contact LIQUIDUS at [email protected]
When you visit the LIQUIDUS website and, more generally, use any of the LIQUIDUS website (the Site and/or our
Products and Services (the “Services”), LIQUIDUS may request certain information from you. References to “you” or
“your” refers to individuals whose PI is processed by LIQUIDUS, including by clients with direct or indirect
relationships (such as employees, contingent workers, consultants, officers, agents (together “Representatives” of
LIQUIDUS).
This Privacy Policy sets out the purposes for which LIQUIDUS may collect, use and disclose (collectively
“processing”) PI and how it is treated and protected. Furthermore, it sets out an individuals’ rights in relation to the
processing of their PI.

2. PI LIQUIDUS or our Service Providers may collect about you

For information purposes only and not advice, please always seek independent advice. PI is information relating to
an individual, which can be used either alone or with other sources of information to identify that individual. PI does
not include information where the identity of the individual or the specific detail of the information has been removed
and is therefore anonymous. Sensitive personal information (SPI) is a sub-category of PI that includes PI relating to
race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union
membership, information about health and genetic and biometric data, none of which LIQUIDUS collects.

The nature of the information that LIQUIDUS or our Service Providers may collect will depend on the Products and
Services LIQUIDUS provide and LIQUIDUS ’s relationship with you. PI that may be processed by LIQUIDUS is
categorised as follows (the PI listed for each category is non-exhaustive examples):
•Identification data - Full name, title, date of birth
•Contact data - Personal address, telephone number, email address
•Electronic Monitoring data - To the extent permitted by law, LIQUIDUS my record and monitor your
electronic communications with LIQUIDUS
•Financial data - Bank account number and details; credit card number and details
•Marketing and Communications data - Marketing and communication preferences; tracking data relating to
whether you have read marketing communications from LIQUIDUS (please also see our cookies policy.
•Professional Information data - Position/job title, work address; telephone number; email address, sector
and area
•Profile data - Username and password for our online services that you have access to; Services requested;
marketing communications responded to; survey responses
•Services data - Payment details to and from you; details of services you have provided to LIQUIDUS and
LIQUIDUS have provided to you
•Product data – details about products you have used, purchased, interacted with and the ways you may
interact with our Products
•Site data – any interaction and data usage or upload onto or with our Site.
•Technical data - Your use of and interaction with our Site, Products and Services including your IP address,
browser type, browser type, browser plug in types and versions, operating system, data and technical
data inputs and outputs, information you provide onto the platform or download from the platform.
•Sensitive Personal Information (SPI) – LIQUIDUS will never collect Sensitive Personal Information.

3. LIQUIDUS may collect PI in relation to you in the following ways:

•when you provide it to LIQUIDUS in connection with interaction with the LIQUIDUS Site, Products or
Services, such as a completed account application, system interaction and usage, order, download or
purchase
•throughout the course of the relationship with you, including where you change your details, provide
additional PI, or where the services LIQUIDUS are providing to you change
•from public sources where you have manifestly chosen to make your PI public, including via public profiles
on social media, articles, marketing and through any other platforms or mediums
•from visits to the LIQUIDUS Site or through logging into any of LIQUIDUS Services or password protected
areas and usage or purchase of LIQUIDUS Products.

LIQUIDUS may also create or derive PI such as creating records of your interactions with LIQUIDUS, subject to and
to the extent allowed by applicable law.
Unless LIQUIDUS otherwise indicate that the provision of specific PI is optional, any PI requested is necessary for
LIQUIDUS to provide you or your organisation or entity with the Site, Products and Services utilised and/or
requested. If you do not provide the PI requested, LIQUIDUS may not be able to provide access to the Site and
usage or the Products and Services and LIQUIDUS reserves the right not to do so.

4. Purpose and legal basis for processing your PI

The below table sets out the purposes and basis for which LIQUIDUS and our third-party service providers may
process PI.

Category of PI

To consider opening an account andpurchasing Site, Products and Services
Identification data
• Contact data
• Financial data
• Profile data
• Services data
Performance of a contract
• Legal or regulatory obligation
• Legitimate interests: ensuring
LIQUIDUS do not accept or assist or
further any fraudulent or any unlawful
activities, such as terrorism or money
laundering
To deliver the Site, Products andServices you have requested
• Identification data
• Contact data
• Financial data
• Profile data
• Services data
• Technical data
• Marketing & Communications data
Performance of a contract
• Legal or regulatory obligation
• Legitimate interests: ensuring that
you are provided with the best client
services and visitor services
LIQUIDUS can offer, and securing a
prompt payment of any fees, costs
and debts in respect of our Services
To manage payments, fees andcharges and to collect and recovermoney owed
• Identification data
• Contact data
• Financial data
• Services datainside of a div block.
• Performance of a contract
• Legitimate interests: ensuring
LIQUIDUS can manage payments,
fees and charges and to collect and
recover money owed
To manage the relationship with you which will include notifying you about changes to LIQUIDUS terms of business or this Privacy Policy
• Identification data
• Contact data
• Profile data
• Marketing and Communications data
Performance of a contract
• Legal or regulatory obligation
• Legitimate interests: ensuring
LIQUIDUS can notify you about
changes to LIQUIDUS terms of
business or this Privacy Policy
(Where applicable) To interact with governmental or regulatory bodies or other competent national authorities

Processing purpose

Identification data
• Contact data
• Financial data
• Services data
• Legal or regulatory obligation
• Public interest
To detect or prevent fraud and/orother criminal activity and to protect the company and company assets
• Identification data
• Contact data
• Profile data
• Technical data
• Marketing & Communications data
Legal or regulatory obligation
• Public interest
• Legitimate interests: protecting
LIQUIDUS detecting, and protecting
against breaches of LIQUIDUS’s
policies and applicable laws
• Review and update to ensure the
systems and Services are adequate
To manage and protect LIQUIDUSbusiness, including improving datasecurity, troubleshooting data andsystems, system maintenance andtesting, data hosting, managing ouroffices and other facilities
Identification data
• Contact data
• Profile data
• Technical data
• Marketing & Communications data
• Legal or regulatory obligation• Legitimate interests: ensuring theefficient and secure running of LIQUIDUS business, including through office and facilities administration, maintaining information technology services, network and data security and fraud prevention
To invite you to take part in marketinsight or other events or similarevents, and to manage yourparticipation in them
Identification data
• Contact data
• Profile data
• Technical data
• Marketing & Communications data
Legitimate interests: reviewing how
clients use, and what they think of,
LIQUIDUS services; identifying ways
to improve and expand LIQUIDUS
business
Legitimate interests: ensuring
LIQUIDUS client records are up-todate; promoting LIQUIDUS ’s client
services; receiving feedback;
improving LIQUIDUS ’s services;
identifying ways to expand LIQUIDUS
business
To send you marketing (including bypaper and electronic channels)communications and serviceupdates.
Identification data
• Contact data
• Profile data
• Technical data
• Marketing & Communications data

Basis of Processing

In relation to vendor services (as applicable):

Purpose and/or activity

Type of data

Legal basis for processing

To engage you or the organisationor entity you work for as a newsupplier, including performingbackground checks
• Identification data
• Profile data
• Contact data
• Financial data
• Services data
This is some tex• Performance of a contract
• Legal or regulatory obligation
• Legitimate interests: ensuring
LIQUIDUS do not deal with
proceeds of criminal activities or
assist in any other unlawful or
fraudulent activities for example
money laundering or terrorism
• Public interestt inside of a div block.

5. To whom LIQUIDUS disclose your PI

In connection with one or more of the purposes outlined in the section ‘Purpose and Legal basis for processing your
PI’ above, LIQUIDUS may disclose PI to:

•professional advisors, third parties, agents or independent contractors that provide services to LIQUIDUS
(including, but not limited to: legal representatives, professional consultants, consultants, contractors,
parts suppliers, services suppliers, third party agencies and individuals), which includes their
professional advisors, third parties, agents, independent contractors that provide services to them (such
as IT systems providers, payment services providers, platform providers, financial advisors, payment
processors, brokers, consultants (including legal representatives and accountants);
•goods and services providers (such as providers of marketing services where LIQUIDUS are permitted to
disclose your personal information to them); payment processors, intermediaries, brokers, and other
individuals and entities that partner with LIQUIDUS;
•competent authorities (including any national and/or international regulatory or enforcement body, agency,
court or other form of tribunal or tax authority) or their agents where LIQUIDUS is required or allowed to
do so under applicable law or regulation;
•(where applicable) a potential buyer, transferee, merger partner or seller and their advisers in connection
with an actual or potential transfer or merger of part or all of LIQUIDUS’s business or assets, or any
associated rights or interests, or to acquire a business or enter into a merger with it;
•(where applicable) credit reference agencies (including professional and retail agencies) or other
organisations that may help LIQUIDUS to provide data, Products and Services and also to conduct antimoney laundering and anti-terrorist financing checks and to detect fraud and other potential criminal
activity; or
•any person to whom disclosure is allowed or required by local or foreign law, regulation or any other
applicable instrument or agency.

6. Marketing and exercising your right to opt-out of marketing

LIQUIDUS will not process your PI for marketing purposes if you have informed LIQUIDUS that you do not wish to
receive marketing materials. You can request that LIQUIDUS stop processing your PI for marketing purposes at any
time by clicking on marketing opt-out links in any electronic marketing materials LIQUIDUS send you (unsubscribe)
and/or by using the contact details set out in the “Contacting LIQUIDUS” section of this Privacy Policy.

7. Third-party marketing/sale of PI

LIQUIDUS do not share or sell your PI to third parties for the third-party to use for their own marketing or other
purposes.

8. PI retention

LIQUIDUS will process your PI for as long as is necessary to fulfil the purpose for which it was collected including to
fulfil Site, Products and Services, until you opt-out or until Liquidus has met its obligations, for example to comply
with legal, regulatory, accounting, auditing, reporting, internal policy requirements or for the establishment or defence
of legal claims.

9. PI security

LIQUIDUS may use a range of physical, electronic, and managerial measures to ensure a level of security appropriate
to the risk of PI processing. These measures may include any or all the following:
•education and training of relevant staff to ensure they are aware of LIQUIDUS privacy obligations when
processing PI as well as training around social engineering, phishing, spear phishing, and password
risks;
•the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems
and services;
•the ability to restore the availability and access to PI in a timely manner in the event of a physical or
technical incident;
•administrative and technical controls to restrict access to and process PI;
•technological security measures, including firewalls, encryption, and anti-virus software;
•segregation of networks and backup facilities;
•application security;
•endpoint security;
•real-time monitoring of data leakage controls;
•layered and comprehensive cybersecurity defences; and
•security incident reporting and management.
The security of data transmitted over the internet (including by e-mail) cannot be guaranteed and carries a risk of
access and interception by third parties. LIQUIDUS endeavour to protect personal information but cannot guarantee
the security of data transmitted to LIQUIDUS or by LIQUIDUS.

10.Your rights

In certain circumstances you may have the following rights in relation to the processing of your PI:
•Access: To request a copy of the PI LIQUIDUS process in relation to you and to be informed about how
LIQUIDUS use and (where applicable) share your PI – subject to any legal and regulatory obligations.
•Object: To object to the processing of your PI if (i) LIQUIDUS are processing your PI on the grounds of
legitimate interests or for the performance of a task in the public interest (including profiling); or (ii) if
LIQUIDUS are processing your PI for direct marketing purposes.
•Correction: To request that LIQUIDUS update the PI it processes in relation to you, or to correct PI that you
think is incorrect or incomplete.
•Erasure: To ask that LIQUIDUS delete PI that LIQUIDUS process in relation to you where LIQUIDUS do not
have a legal or regulatory obligation or other valid reason to continue to process or retain it.
•Restriction: To request that LIQUIDUS restrict the way in which LIQUIDUS processes your PI, for example,
if you dispute the accuracy of your PI or have raised an objection which is under consideration.
•Portability: To request a copy of your PI that you have provided to LIQUIDUS in a commonly used electronic
format such as through the completion of an application form.
•Automated decision making: To request manual intervention if you are subject to automated decisions
where the decision results in a legal or similar effect to you.
You may exercise your rights at any time by using the details set out in the Contacting LIQUIDUS section. To the
extent permitted by applicable law or regulation LIQUIDUS reserve the right to charge an appropriate fee in
connection with you exercising your rights.
LIQUIDUS may need to request specific information from you to help LIQUIDUS confirm your identity and ensure
your right to access to the PI requested, or to exercise any of your other rights. This is to ensure that PI is not
disclosed to any person who does not have authority to receive it. LIQUIDUS may also request further information in
relation to your request to help LIQUIDUS to locate the PI processed in relation to you, including, for example, the
nature of your relationship with LIQUIDUS.
LIQUIDUS aim to respond to all legitimate requests within one calendar month. If LIQUIDUS think it may take longer
than one calendar month, (such as where your request is particularly complex or you have made a number of
requests), LIQUIDUS will notify you and keep you updated. You will not be disadvantaged in any way by exercising
your rights in relation to the processing of your PI.

11.Contacting LIQUIDUS

If you wish to exercise any of your rights or have any questions concerning this policy, please contact:
[email protected] You also have a right to complain to a data protection or other competent authority with
jurisdiction over privacy and data protection law in the country you live or work, or in the country where you believe
an issue in relation to the processing of your PI has arisen. Please contact [email protected] for further
details.

12.Linked websites

This Privacy Policy is not applicable to third-party websites that LIQUIDUS do not own or control (including those
that are linked, hyperlinked or otherwise to products, policies, terms, warranties, or any other information
whatsoever), or to any third-party website where LIQUIDUS advertisements and marketing are displayed.
13.Changes to this Privacy Policy
LIQUIDUS may modify or amend this Privacy Policy from time to time and you are advised to visit our website and
Privacy Policy regularly to check for any amendments and updates. Any material changes will be communicated to
you through an appropriate channel, depending on how LIQUIDUS normally communicate with you. It is your
responsibility to ensure that you remain informed of our policies when interacting with any Liquidus Site, Products or
Services.