Your Privacy Rights
EFFECTIVE DATE: [JANUARY 25, 2019]
Liberis Finance (“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.
1. What Information Do We Collect?
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:
- Percentage of ownership in the business
- Home street address
- Telephone number
- Email address
- Social security number
- Date of birth
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.
2. 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.
3. How We Use Your Personal Information
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.
4. How we may share and disclose your personal information
4.1 Liberis shares your personal information with third parties as permitted by law, including in the following ways:
- Third party service providers. We may work with third party service providers, including affiliates, to support our business functions, such as facilitating electronic fund transfers and offering customer service. For example, we will work with companies that we partner with to provide services to you, and companies that we work with to collect information about your card transactions. Liberis may share your personal information, including credit reports, with such companies, but all service providers acting on our behalf will only process your data in accordance with instructions from us and will comply fully with relevant data protection laws and any other appropriate confidentiality and security measures.
- Credit reporting agencies. Liberis may share personal information about you with CRAs or other data-collection organizations to meet our reporting obligations.Other affiliates and third parties. We may also share your personal information, other than credit reports, with affiliates and third parties that are not affiliated with us for any legitimate purpose permitted by applicable law.
4.2 We may also share aggregated and anonymized data sets based on your personal information with third parties that does not reasonably identify you directly as an individual.
5. Cookies and Similar Technologies
- 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.
6. 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.
7. 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.
8. 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.
For questions, contact us at firstname.lastname@example.org ,or call us at (844) 754-2370.
10. Your California Privacy Rights
10.1 California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com. Please note that we are only required to respond to one request per customer each year. We will not sell or share your Personal Information with non-affiliated companies for their direct marketing purposes without your consent.