LiquidFi Privacy Policy
Last Updated: January 7, 2022
LiquidFi, Inc. ("LiquidFi," "we," or "us") is a data management and analytics provider that offers a seamless blockchain-based solution for end-to-end loan validation, documentation, and payments in the lending industry (collectively, the "LiquidFi Platform"). We are a service provider to loan transaction parties such as mortgage-backed securities issuers and institutional investors. This Privacy Policy explains how LiquidFi collects, uses and discloses information to provide the LiquidFi Platform to our clients and otherwise for our own business purposes, such as to operate the LiquidFi Platform, improve the quality of our offerings and promote our offerings to potential customers. For information about how our clients collect, use and disclose information handled through their use of the LiquidFi Platform, such as Loan Information (defined below in the section entitled "Other Information"), please refer to their own separate privacy notices and policies.
This Privacy Policy describes our practices in connection with information that we collect through:
- Websites operated by us from which you are accessing this Privacy Policy (the "Websites");
- The LiquidFi Platform, accessible at www.liquidfi.io;
- Our social media pages, including LinkedIn (https://www.linkedin.com/company/liquidfi-inc) and Twitter (https://twitter.com/LiquidFi_Inc)(collectively, our "Social Media Pages"); and
- HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you.
Collectively, we refer to the Websites, LiquidFi Platform, Social Media Pages, and emails as the "Services."
PERSONAL INFORMATION
"Personal Information" is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including:
- Name
- Contact information (ex. Business address, telephone, e-mail address)
- Company information (ex. employer, industry, role)
- LiquidFi Platform account credentials (i.e. username and password)
- IP address (we may also derive your approximate location from your IP address)
Collection of Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
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Through the Services.
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We collect Personal Information through the Services, for example, when you sign up for a newsletter, register an account to access the Services, visit our Websites, attend one of our events, or contact one of our team members or general information e-mail.
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From Other Sources.
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We receive your Personal Information from other sources, for example:
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Publicly available databases; and
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Our Social Media pages.
We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services.
Use of Personal Information
We and our service providers use Personal Information for the following purposes:
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Providing the functionality of the Services and fulfilling your requests.
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To provide the Services' functionality to you, such as arranging access to your registered account, and providing you with customer service.
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To respond to your inquiries and fulfill your requests, when you contact us via e-mail or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services.
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To complete your transactions, verify your information, and provide you with related customer service.
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To send administrative information to you, such as changes to our terms, conditions, and policies.
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Providing you with marketing materials.
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To send you marketing related emails and/or newsletters, with information about our services, new products and other news about our company.
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To facilitate social sharing functionality that you choose to use.
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Aggregating and/or anonymizing Personal Information.
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We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
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Accomplishing our business purposes.
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For data analysis, for example, to improve the efficiency of our Services;
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For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
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For fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
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For developing new products and services;
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For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures;
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For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
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For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
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For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users' interests.
Disclosure of Personal Information
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By using the Services, you may elect to disclose Personal Information.
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The LiquidFi Platform is a blockchain-based platform, and any information provided will be visible to users of the Platform.
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To our third party service providers, to facilitate services they provide to us.
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These can include providers of services such as website hosting, data analysis, payment processing, marketing, fraud prevention, information technology and related infrastructure provision, , email delivery, auditing, and other services.
Other Uses and Disclosures
We may also use and disclose Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, to respond to requests from public and government authorities, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions; and © to protect our rights, privacy, safety or property, and/or that of, you, or others. We may use, disclose or transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our assets or stock (including in connection with any bankruptcy or similar proceedings).
OTHER INFORMATION
"Other Information" is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:
- De-identified loan information, including loan ID loan numbers, loan amounts, loan payments, amortization schedules and other specific loan information (collectively "Loan Information"). Loan Information is not personally identifiable from LiquidFi's perspective; however, certain users of the LM Platform, such as securitization issuers and/or loan servicers, are able to identify specific borrowers by connecting loan ID numbers that are available in the LiquidFi Platform with personally identifiable loan information that they have in their own records.
- Browser and device information
- App usage data
- Information collected through cookies, pixel tags and other technologies
- Demographic information and other information provided by you that does not reveal your specific identity
- Information that has been aggregated in a manner such that it no longer reveals your specific identity
Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
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From issuers of securitizations and loan servicers
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Loan Information is submitted by issuers of securitizations and/or servicers. By submitting Loan Information to us, these users give LiquidFi the right to make it available via the LiquidFi Platform to other users of the LiquidFi Platform, including issuers of securitizations and servicers who have the ability to connect Loan Information to specific borrowers using their own records
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Your browser or device.
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Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
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Your use of the LiquidFi Platform.
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When you use the LiquidFi Platform, we and our service providers may track and collect usage data, such as the date and time of access to our servers and [what information and files have been downloaded based on your device number].
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Cookies.
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Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.
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Analytics
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We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google's practices by going to www.google.com/policies/privacy/partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
SECURITY
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the "Contacting Us" section below.
MARKETING EMAILS
If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by clicking on the "Unsubscribe" link We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.
THIRD PARTY SERVICES
This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any of our customers to whom we provide the LiquidFi Platform or third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us.
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.
JURISDICTION AND CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
SENSITIVE INFORMATION
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or criminal background, on or through the Services or otherwise to us.
UPDATES TO THIS PRIVACY POLICY
The "Last Updated" legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. In some cases we may contact you to give you choice about a change that we make to this Privacy Policy.
CONTACTING US
If you have any questions about this Privacy Policy, please contact us at info@liquidfi.io.
Because email communications are not always secure, please do not include sensitive information in your emails to us.