CCPA

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT

Recently updated March, 2023

APPLICABILITY

This CCPA privacy notice (“CCPA Notice”) for California Residents under the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 effective January 1, 2023 (“CPRA”), supplements the information contained in Liquidity Capital MC Ltd. Privacy Policy and applies to our website Visitors or Platform Users (as defined under the Privacy Policy), who are residents in the State of California (“consumers” or “you”)

This CCPA Notice applies to California residents’ Personal Information, which we collect directly or indirectly as a Business.

Any terms defined in the CCPA and CPRA have the same meaning when used in this CCPA Notice. Further, this CCPA Notice is an integral part of our Privacy Policy and thus, definitions used herein but not defined herein shall have the meaning ascribed to them in our Privacy Policy.

A COMPREHENSIVE DESCRIPTION OF THE INFORMATION PRACTICES:

(1)     Categories Of Personal Information We Collect

Under the CCPA, “Personal Information” is defined as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular consumer, household or device. Personal Information further includes Sensitive Personal Information (“SPI”).

The categories of Personal Information that we collect (and have collected within the last 12 months), are included in the table below. For full information regarding the types of data we collect, please review our Privacy Policy.

Please note that, under the CCPA Personal Information does not include: publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; information excluded from the CCPA’s or CPRA’s scope such as: health or medical information covered by applicable laws such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA),the California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.

Category
Examples of Personal Information
Do we Collect this Data?
A. Identifiers.
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
Yes
A real name, unique personal identifier, online identifier, Internet Protocol address, email address, account name.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.
Yes
A name, telephone number, education, employment, employment history.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Not Collected
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Not Collected
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Not Collected
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Yes
Information on a consumer's interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location, approximate location derived from IP address or movements.
YES
Approximate location from IP address.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
Not Collected
I. Professional or employment-related information.
Current or past job history or performance evaluations.
Yes
In the event you are interested in joining our team or apply for a position posted on our website.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Not Collected
K. Inferences drawn from other personal information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Not Collected
L. Sensitive personal information.
Government-issued identifying numbers, financial account details, genetic data, precise geolocation, race or ethnicity, religious or philosophical beliefs, union membership, mail, email, text messages, biometric data, health data, and sexual orientation or sex life.
Not Collected

(2) Disclosures Of Personal Information for a Business Purpose

We may disclose your Personal Information to a contractor or service provider for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. We further restrict the contractor and service provider from selling or sharing your Personal Information. In the preceding twelve (12) months, the Company has disclosed the following categories of Personal Information for a business purpose:

‍

Category (corresponding with the table above)
Category of Recipient
Business Purpose
1
2
3
Category A
Category B
Category F
Category G
Category I
Cloud computing and storage vendors.
Government entities/Law enforcement.
Operating systems.
Data analysis providers.
Storage, hosting.
Subject to a law requirement, such as tax authorities.
Operating the Platform and website.
4
Category A
Category F
Category G
Dataanalysis providers.
Providing  analytic data on the use of our website. We limit the providers ability to  share such information, as detailed above.
6
Category A
Category B
Category F
Category G
Marketing & promotions providers, CRM providers, social networks, advertising networks.
Marketing which is not cross-contextual, ad delivery.
7
Category A
Category F
Security service providers.
Debugging, security, fraud prevention.
9
Category A
Category B
Category F
Category G
Category I
Customer support providers. Affiliated companies.
Customer and technical support.

(3) How We Collect Personal Information

We collect the categories of Personal Information detailed above, in the following ways:

  • Directly from you: for example, from forms you complete, when you contact us, etc.;
  • Directly and indirectly from activity on our website: for example, directly from you when you inquire about our Platform, or indirectly, we collect your usage data automatically from measurement tools;
  • Indirectly from you: we track your activities across the internet related to engagement with our campaigns, for example, when you view or interact with certain content, web page or ad.

(4)     Use Of Personal Information

We may use, or disclose the Personal Information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason you provided the Personal Information. For example, if you contact us with an inquiry and share your name and contact information, we will use that Personal Information to respond to your inquiry, review your CV considered for a job position, etc.;
  • For security and fraud detection purposes, monitoring and to maintain the safety, security, and integrity of our website and Platform;
  • To improve our business operation, which includes but not limited to, analyze which types of content should be provided as part of the website; marketing; analyzing your use of the website;
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
  • As described to you when collecting your Personal Information or as otherwise set forth in the Privacy Policy.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

(5)     Sale of Personal Information

We do not “sell” information as most people would commonly understand that term, we do not, and will not, disclose your Personal Information in direct exchange for money or some other form of payment.  We may “share” Personal Information for “interest-based advertising” or “cross-context behavioral advertising”. The CCPA defines “sharing” as “communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information” to “a third party for cross-context behavioral advertising, whether or not for money or other valuable consideration”. In other words, we may share your Personal Information with a third party to help serve personalized content or ads that may be more relevant to your interests, and to perform other advertising-related services such as enabling our partners to serve such personalized content

In the preceding twelve (12) months, we “sell” or “share” the following categories of Personal Information for a business purpose:

‍

Category (corresponding with the table above)
Category Recipient
Purpose of Sale or Share
Category A
Category F
Category G
Ad-network and advertising partners.
Sale/Share for cross-context behavioral advertising.

(6)     Amendments

This notice was last updated on April 2023, as required under the CCPA, we will update this Privacy Notice every 12 months. The last revision date will be reflected in the “Last Modified” heading located at the header of the Privacy Notice.

(7)     ChildrenUnder Age 16

We do not knowingly collect information from children under the age of 16.

(8)     DataRetention

In general, we retain the Personal Information we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you express your preference to optout, where applicable.

The retention periods are determined according to the following criteria:

  • For as long as it remains necessary in order to achieve the purpose for which the Personal Information was initially processed. For example, if you contacted us, we will retain your contact information at least until we will address your inquiry.
  • To comply with our regulatory obligations. For example, transactional data will be usually retained for seven years as of termination of engagement (or even more under certain circumstances) for compliance with our bookkeeping obligations purposes.
  • To resolve a claim we might have or a dispute with you, including any legal proceeding between us, until such dispute will be resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods.

Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.

EXPLANATION OF YOUR RIGHTS UNDER THE CCPA and how to exercise them

(1)     Your Rights, Choices and Controls Related to Your Personal Information Under the CCPA

If you are a California resident, you may exercise certain privacy rights related to your Personal Information. You may exercise these rights free of charge except as otherwise permitted under applicable law. We may limit our response to your exercise of these privacy rights as permitted under applicable law, all as detailed herein and in the Data Subject Request Form available HERE.

‍

California Privacy Right
Details
The right to know what Personal Information the business has collected.
The  right to know what Personal Information the business  has collected about the consumer, including the categories of Personal  Information, the categories of sources from which the Personal Information is  collected, the business or commercial purpose for collecting, selling, or  sharing Personal Information, the categories of third parties to whom the  business discloses Personal Information, and the specific pieces of Personal  Information the business has collected about the consumer.
Deletion rights.
The right to delete Personal Information that the business has collected from the consumer, subject to certain exceptions.
Correct inaccurate information
The right to correct inaccurate Personal Information that a business maintains about a consumer.
Opt-Out of sharing for cross-contextual behavioral advertising
You have the right to opt-out of the “sharing” of your Personal Information for “cross-contextual behavioral advertising”, often referred to as “interest-based advertising” or “targeted advertising”.
Opt-out from selling
the right to opt-out of the sale or sharing of Personal Information by the business.
Limit the Use or Disclosure of SPI
Under certain circumstances, If the business uses or discloses SPI, the right to limit the use or disclosure of SPI by the business.
Opt-out of the use of automated decision making
In certain circumstances, you have the right to opt-out of the use of automated decision making in relation to your Personal Information.
Non-discrimination
The  right not to receive discriminatory treatment by the business for the  exercise of privacy rights conferred by the CCPA, including an employee’s,  applicants, or independent contractor’s right not to be retaliated against  for the exercise of their CCPA rights, denying a consumer goods or services,  charging different prices or rates for goods or services, providing you a  different level or quality of goods or services, etc. We may, however, charge  different prices or rates, or provide a different level or quality of goods  or services, if that difference is reasonably related to the value provided  to us by your Personal Information.
Data portability
You may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including, where applicable, to obtain a copy of the Personal Information you provided to us in a portable format.

To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws

(2)     How CanYou Exercise the Rights?

We provide option to opt out of Sharing for Cross-Contextual Behavioral Advertising or Selling Personal Information by using the following opt-out options:

  • Use the cookies setting tool on our website.
  • California and Colorado resident and wish to opt-out from having your data used for interest-based advertising, you may exercise your right here: https://optout.privacyrights.info/.

Other rights may be exercised by using the Data Subject Request Form HERE. The instructions for submission, the general description of the process, verification requirements, when applicable, including any information the consumer or employee must provide are all detailed therein.

(3)     Authorized Agents

“Authorized Agents” may submit opt out requests on a consumer’s behalf. If you have elected to use an authorized agent, or if you are an authorized agent who would like to submit requests on behalf of a consumer, the following procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California consumer. Usually, we will accept requests from qualified third parties on behalf of other consumers, regardless of either the consumer or the authorized agent’s state of residence, provided that the third party successfully completes the following qualification procedures:

  • When a consumer uses an authorized agent to submit a request to know or a request to delete, a business may require that the consumer do the following:
    - Provide the authorized agent signed permission to do so or power of attorney.
    - Verify their own identity directly with the business.
    - Directly confirm with the business that they provided the authorized agent permission to submit the request.
  • A business may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf.

(4)     Notice Of Financial Incentive

We do not offer financial incentives to consumers for providing Personal Information.

OTHER CALIFORNIA OBLIGATIONS

(1)     Direct Marketing Requests:

California Civil Code Section 1798.83 permits you, if you are a California resident, to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please use the Data Subject Request Form available HERE

(2)     Do Not Track Settings:

Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we so not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us.

(3)     California’s “Shine the Light” law (Civil Code Section § 1798.83):

Permits employees that 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 us the Data Subject Request Form HERE

CONTACT US

Please contact us if you have any questions or concerns regarding any privacy issues or if you wish to be provided with any other information regarding our privacy practices, as follows: