Privacy
Policy

Recently updated March, 2023

PRIVACY POLICY

Last Update March 2023.

Liquidity Capital M.C. Ltd. ("Company", "we", "us" or "our") respects your privacy and recognizes that your privacy is important.

This privacy policy("Privacy Policy") explains the Company's practices regarding the collection, processing, usage and transfer of Personal Data, that are applicable towards any visitor of our website ("Visitor"), as well as upon registration, access and use of our Platform (as defined under our Terms &Conditions) by any third party engaged with us for such purpose and any individual on its behalf  ("Platform Users").Visitors and Platform Users will be further referred to as "you" or "user".

This Privacy Policy also provides the required information under the EU General Data Protection Regulation ("GDPR") and the California Consumer Privacy Act of 2018 ("CCPA"), to the extent applicable.

In the event you are a Colorado or California resident – please make sure to review our CCPA Privacy Notice to learn more about our privacy practices with respect to the CCPA.

You are not required by law to provide us with any Personal Data, however, please note, that some of our Services (as defined under our Terms &Conditions) require the processing of certain Personal Data and  without such data we may not be able to provide you with all or  part of the Services.

Data Controller, Data Protection Officer & Representative

Liquidity Capital M.C. Ltd., incorporated under the laws of the State of Israel, is the “Data Controller” (as such term is defined under the GDPR or equivalent privacy legislation) of the Personal Data collected from Visitors and Platform Users with regards to their registration and use of the Service.

If you have any question, inquiry, request or concern related to this Privacy Policy or the processing of your Personal Data, you may contact us and our privacy team as follows:

  • By Email - to our Data Protection Officer at privacy@liquiditygroup.com; or
  • By Mail: Derech Menachem Begin 154, Tel Aviv-Yafo (Attention: Data Protection Officer).

EU Data Protection Representative

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact.

Prighter gives you an easy way to exercise your privacy-related rights (e.g., requests to access or erase Personal Data). If you want to contact us via our representative- Prighter, or make use of your data subject rights, please visit the following website: https://prighter.com/q/13356608436

UK Data Protection Representative

Liquidity Capital UK Limited [AE1] , which you may contact at: privacy@liquiditygroup.com.

The Data We Collect & Our Lawful Basis for Processing Your Personal Data

Depending on your interaction with us, meaning if you browse our website, or register and use the Platform or Services, we collect two types of data:

"Non-Personal Data" meaning, information which does not identify a specific natural person and cannot reasonably be used for such identification. We collect Non-Personal Data regarding use of the website and Platform, such as the scope, frequency, latency, pages accessed and viewed, time and date stamp, interactions with content and materials displayed through our website, language preference, and other technical information regarding the device used to access the website, for example type of device, type of browser, operating system, etc. This data is considered as Non-Personal Data when collected on an aggregate basis, or otherwise not combined with online identifiers.

Also, we may sometimes process and anonymize or aggregate Personal Data and identifiable information in a manner that shall create a new set of data that will be Non-Personal Data. Such a new data set can no longer be associated with any identified natural person.

Non-Personal Data may be used by us without limitation and for any purpose, including for commercial, research, or statistical purposes, in order to maintain and develop our website and Platform, including among others, for ensuring the technical functioning of our website and Platform, to help prevent fraudulent use of the website and Platform, etc.

" Personal Data" meaning, individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual. This may include online identifiers, first and last name, email address, etc.

If we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data.

We have included in the table below information about the types of Personal Data processed, how we process and use Personal Data, the lawful basis for which we do so subject to the GDPR and processing operations.

‍

Type of Data
Purpose of Processing & Operation
Lawful Basis
Data Collected Upon Registration and Use of Our Platform  
If you choose to use our Platform you will be required to provide us with your full name and email address (for signing-up), as well as information related to the entity you sign up on its behalf (i.e., company name, your position, etc.). In addition, we will process email address of additional user, where provided by the Platform Users, for example, where using the “invite a friend” feature, adding authorized users, etc.
We will collect, store and use this information for the purpose of designating your account, and enabling the login process and access to the Platform.
We will further use your contact details in order to send you the required information related to the Services (i.e., operational messages) as well as marketing materials related to our Services (i.e., direct marketing).
Our lawful basis for processing this data is the performance of our contract with you – meaning, to enable the use of the Platform.
Our lawful basis for processing this data is the performance of  our contract with you – meaning, to enable the use of the Platform. Processing for direct marketing purposes is based on our  legitimate interest. You may opt-out at any time through the “unsubscribe”  link within the email or by contacting us directly.  Please note that if you opt-out we will not send you our marketing materials  however we will continue to send you operational related communications.
Device Identifiers and Online Usage When you interact with the website and use our Platform, we will collect online identifiers such as your Internet Protocol address (“IP”), Cookie-ID, etc., as well as other information that relates to your activity through the website and Platform, such as pages viewed, click stream data, login time and date stamp, etc. This data might be collected directly by us or by through our use of third parties' cookies.
Collection of device identifiers is needed for the following purposes:
(i) Website and the Platform’s operation, security and fraud detection purposes, and for example, when you login to our Platform, in order to detect and prevent fraudulent access;(ii) Internal statistics and analysis, for which device identifiers might be combined with usage data, for example, to analyze how many users have accessed certain content and from which country (where the country is extracted from the IP address) in order to enhance and improve our website and its content;
(iii) Marketing and advertising purposes.    
Note that, we do not attempt to analyze or determine your identity based on such information or otherwise combine it with any information such as your name or email address.
Our lawful basis for the processing this data for operation and security purpose  is based on our legitimate interests. Where required under applicable laws, we will obtain your consent for the purpose of data collection through our use of third-party cookies for analytics and advertising purposes.  In any such case, you may withdraw consent or change your preferences at any time by using the cookie settings tool available on our website.
Contact Communications
‍If you voluntarily contact us through any means of  communication we make available (e.g., send us an email, or use any other  online form available on our website or Platform), you will be requested to  provide us with your contact information such as your name, phone number and  email address.
We process your contact information solely  for the purpose of contacting you, responding to your inquiries and provide  you with the support or information you have requested. The correspondence with you may be processed and stored by us in  order to improve our internal operation, as well as in the event we  reasonably determine it is needed for future assistance or to handle any  dispute you might have with us.
Newsletter & Updates Registration
In the event you sign up to receive our newsletter or other promotional materials, you will be requested to provide your contact details, such as email address.
We will use the information you provide in order to include  you in our mailing list and send you the materials you have signed up to  receive.
Our lawful basis for the processing of this data is your consent. You may withdraw your consent at any time by clicking the “unsubscribe” link which will be included in the email we will send you. You may also contact us at: privacy@liquiditygroup.com and request to unsubscribe.
Job Applications
If you wish apply for any  position posted on our website, you will be requested to provide certain  information such as your name, e-mail address, phone number, and your CV. You  may also choose to provide us additional information such as recommendations  from previous employers, your LinkedIn profile, etc.
We collect and process this data in order to examine your resume in the context of managing our recruiting and hiring process. In addition, we will use such information to demonstrate compliance with corporate governance and legal and regulatory requirements .Please note, in the event, you send us your CV, your provision of Personal Data in connection with recruiting is voluntary, and you determine the extent of information you provide us. We do not request or require sensitive personal information concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. If you are hired, the information may be used in connection with employment and corporate management.
Our lawful basis for processing of this data is our legitimate interest.

How We Collect Information

Depending on the nature of your interaction with us, the website and the Platform, we may collect information as follows:

  • Automatically – we may use cookies (as elaborated in the section below) or similar tracking technologies (such as pixels, tags, agent, etc.) to gather some information automatically.
  • Provided by you or about you voluntarily –we will collect information if and when you choose to provide us with the information, such as through online registration, contact us communications, etc. all as detailed in this Privacy Policy.

Cookies

When you access or use the website, we use“ cookies” or similar tracking technologies, which store certain information on your device (i.e., locally stored). The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies are used by us for various purposes, including allowing you to navigate between pages efficiently, as well as for statistical purposes, analytic purposes and advertising. You can find more information about our use of cookies here: www.allaboutcookies.org.

There are several types of cookies, and among others:

  • Essential, Functionality, Operation & Security Cookies. These cookies are essential     for enabling user movement around the website, for the website to function     properly, and for security purposes (i.e., used to authenticate users,     prevent fraudulent use, and protect user data from unauthorized parties). This category of cookies either cannot be disabled, or if disabled, certain features of the website may not work.
  • Analytic, Measurement & Performance Cookies. These cookies are used     to collect information about how users use our website, in order to     improve our website, content, and the way we offer them, as well assess     performance of the content and marketing campaigns. These cookies enable     us, for example, to assess the number of users who have viewed a certain age     as well as their country of origin. It enables our website to remember information that changes the way it behaves or looks, such as your preferred language.
  • Preference, Targeting & Advertising Cookies. These cookies are used to     advertise across the internet and to display relevant ads tailored to     users based on the parts of the website they have (e.g., the cookie will     indicate you have visited a certain webpage and will show you ads relating     to that webpage)

The third party cookies wecurrently use, purpose of use, their privacy policy and opt-out controls areset forth in the link:

You may opt-out of cookies or change your preferences ant any timeby using the cookies setting tool available on our website.

Also note that, most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You may set your browser to block all cookies, including cookies associated with our website, or to indicate when a cookie is being used by us, by adjusting the privacy and security settings of your web browser. Please refer to the support page of your browser to learn more about how you can adjust your privacy and security settings. Please note that once you choose to opt out or disable cookies, some features of the website may not operate properly and your online experience may be limited.

Where we use third-party advertising cookies, such third-party may independently collect, through the use of such tracking technologies, some or all types of Personal Data detailed above, as well as additional data sets, including to combine such information with other information they have independently collected relating to your online activities across their network of websites, for the purpose of enhanced targeting functionality and delivering personalized ads, as well as providing aggregated analytics related to the performance of our advertising campaign you interacted with. These third parties collect and use this information under their own privacy policies, and are responsible for their practices.

Data Sharing – Categories of Recipients We Share Personal Data With

We shareyour Personal Data with third parties, including with trusted partners orservice providers that help us to manage our business operation, website, etc.You can find here information about the categories of such third-party recipients.

Categories of Recipients
Additional Information
Our Affiliated Companies
We may share Personal Data with our affiliated companies and subsidiaries in  order to provide joint services, for example, marketing, customer support,  recruitment, etc. We may further   share certain types of Personal Data about  you as may be necessary to help detect and prevent potentially illegal acts,  violations of our policies, fraud and/or data security breaches.  
Our Service Providers
We share your Personal Data with our trusted service providers and  business partners that perform business operations for us on our behalf (as  data processors) and pursuant to our instructions.
This includes the following categories of service providers:
‍
●  Advertising and  marketing service providers, who help us with advertising measurements, email  marketing, etc.;
● Data storage providers, with whom we  entrust the hosting and storage of our data;
● Customer support  providers, who help us perform such functions as customer support and customer  service;  
● Data analytics and data  management providers, who help us improve, personalize and enhance our  operation;
● Data security partners, who help us  detect and prevent potentially illegal acts, violations of our policies,  fraud and/or data security breaches and ensure compliance with legal  obligations.
Legal and Law Enforcement
We may disclose certain Personal Data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose.
Corporate Transactions
In the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale) we will share the Personal Data we store with our acquiring company.
We will obligate the acquiring company to assume the rights and obligations as described in our Privacy Policy.

Where we share Personal Data with services providers and partners, we ensure they only have access to such information that is strictly necessary in order for us to provide the services of fulfil the purpose for which data was shared. These parties are required to secure the Personal Data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with applicable data protection regulations (note that, such service providers may use other Non-Personal Data for their own benefit).

Cross-Border Data Transfer

Due to our global business operation, we may store or process your Personal Data in several territories, including, for example in Israel, the UK, EU, US or in other countries. Thus, your Personal Data may be transferred to and processed in countries other than the country from which you accessed our websites or otherwise the country of your jurisdiction. We will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer. Where Personal Data collected from within the EU or UK, is being transferred outside such territories to countries which didn’t receive an adequacy decision on behalf of an authorized authority (such as the EU Commission), we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the standard contractual clauses approved by the European Union or the UK Information Commissioner’s Office . Thus, we will obtain contractual commitments or assurances from the data importer to protect your Personal Data, using contractual protections that EEA and UK regulators have pre-approved to ensure your data is protected (known as standard contract clauses), or rely on adequacy decisions issued by the European Commission. Some of these assurances are well-recognized certification schemes

Data Retention

We retain the Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out.

In certain circumstances, we will retain your Personal Data for longer periods of time and mainly:

  • Where we are required to retain Personal Data in accordance with legal, regulatory, tax, or accounting requirements;
  • Where we deem retention is necessary to obtain an accurate record of your dealings with us in the event of any complaints or challenges; or
  • Where we deem retention is necessary to obtain an accurate record of your dealings with us in the event of any complaints or challenges; or

We may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

Privacy Rights

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. We provide you with the ability to exercise certain choices, rights and controls in connection with your Personal Data. Depending on your relationship with us (e.g., if you are a visitor of our website or a Platform User), your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.

For detailed information on your rights and how to exercise your rights, please see the Data Subject Request (“DSR”) form available HERE [ , and send it to our privacy team at: privacy@liquiditygroup.com.

Certain rights can be easily executed independently by you without the need to fill out the DSR form, and for example:

  • You can you can opt-out from receiving our marketing emails by clicking “unsubscribe” link;
  • You can use the cookie settings tool on our website to change your preferences.

If you are an EU resident, you may also submit the request to exercise your right to our EU Data Protection Representative, Prighter Group, at https://prighter.com/q/13356608436

Where we are not able to provide you with the information for which you have asked, we will endeavour to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority (in the event you are EEA resident). We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law.

Security 

We take great care in implementing and maintaining the security of our website, our Platform, users’ Personal Data. We employ industry standard procedures and policies to ensure the safety of individuals’ information and prevent unauthorized use of any such.

We have implemented technical, physical and administrative security measures to protect the Personal Data we process. In addition, we limit access to Personal Data stored by us.

Please contact us at: privacy@liquiditygroup.com, if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy, or if you become aware of a third party's attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

‍Third Party Websites

Our Privacy Policy only addresses the use and disclosure of Personal Data we collect from you. To the extent that you disclose your Personal Data to other parties via the website (e.g., by clicking on a link to any other website or location), different rules may apply to their use or disclosure of the Personal Data you disclose to them, and this Privacy Policy does not apply to any such third-party products and services. You agree that we shall have no liability whatsoever with respect to such third-party sites and your usage of them.

‍
‍Children’s Data

The website and the Platform are not intended for individuals under the age of eighteen (18). Accordingly, we do not knowingly solicit Personal Data from or market to children as defined under applicable law. We request that such individuals do not provide Personal Data. If you become aware or have any reason to believe that a child has shared any Personal Data with us, please contact us through the means of contact detailed herein.

Changes and Updates

We reserve the right to change this Privacy Policy at any time, so please re-visit this page frequently. In the event of any substantial change of this Privacy Policy, we will make reasonable efforts to post a clear notice on the website, and obtain your consent where required  under applicable. Changes to this Privacy Policy are effective as of the stated “Last Updated” date and your continued thereafter will constitute acceptance of, and agreement to be bound by, those changes.