Last Update: 04 October 2019
- Governing law
- The data we collect from you
- Why we collect your data
- How your data is collected
- Where your data will be stored
- Who will have access to your data
- How long will we keep your data
- Emails and communications
- Third parties and Marketing
- Our disclosure obligations
- Your data protection rights under Bahamian law
- EU Citizens
- Sale or Bankruptcy
- Force majeure
- How to contact us with an inquiry, complaint or access request
- How to contact the relevant authorities
- Privacy policies of other webpages
As Liquidus is based in The Bahamas and is considered a ‘data controller’, this Policy is governed by the data protection laws of the Commonwealth of The Bahamas, namely the Data Protection (Privacy of Personal Information) Act (‘DPA’). We also note that citizens of the European Union (‘EU’) benefit from distinct global data privacy rights under the General Data Protection Regulation (‘GDPR’). In recognition of this, our company is GDPR-compliant. Data access requests made by EU citizens will be handled in accordance with the GDPR.
THE DATA WE COLLECT FROM YOU
We collect and process the following data once you access our website or enter information into a web-form on our page:
- Website usage information including the frequency of your access to our webpages;
- Websites that you have visited prior to and after accessing our website;
- The Internet browser that you use to access our website;
- Internet Protocol (IP) address;
- E-mail address;
- Company name;
- Mobile device data;
- Geo-location information;
- Mobile device information;
- Push notification information.
WHY WE COLLECT YOUR DATA
Any data that we collect from you as a web visitor is to improve our website and mobile app experience. It is also used to improve the platform, services and solutions we offer you. The data collected on you will be primarily viewed on an aggregate basis for web-analytic purposes. We will not disclose to third parties any information that could be used to identify you personally.
HOW YOUR DATA IS COLLECTED
We also use Google Analytics to help us understand how our customers use our website – you can read more about how Google uses your personal information by clicking this link.
Please note that we do not alter our website’s data collection and use practices when we see a Do-Not-Track signal from your browser.
Liquidus is fundamentally a Digital Corporate Services Platform that aims to connect businesses with a marketplace of corporate services. By agreeing to this Policy you will be deemed to have acknowledged that we are not responsible for any data that is, has, or will be collected from you by a service provider utilizing the marketplace. Any data that is, has or will be collected from you by a service provider facilitated by the platform is not covered by this Policy.
WHERE YOUR DATA WILL BE STORED
We securely store your data in servers physically located in The United States. Data is stored in secure drives with a registered third party hosting supplier – LiquidWeb. Best practices are employed, such as: 24hrs security monitoring software, SSL site certificates, security patches, access permissions and privileges, backups and two-factor password authentication.
WHO WILL HAVE ACCESS TO YOUR DATA
Employees of Liquidus may view and use your data solely in the course of business in order to provide you with the best service. As our servers are physically located in The United States, we may also share any relevant data to comply with any applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
EMAILS, NEWSLETTERS AND COMMUNICATIONS
You will never be automatically signed up for access to the client-portal portion of our webpage, nor for any newsletter or email correspondence. You will be deemed to have consented to provide us with information requested of you once you click ‘OK’ or ‘Accept’ or ‘Agree’ after having filled out a web form. If you sign up to receive our emails, promotional materials, newsletters or any other relevant Liquidus communications you will have the option to opt-out at any time as per your rights under the DPA and GDPR.
THIRD PARTIES AND MARKETING
We do not share personally identifiable visitor data with any third parties for marketing purposes. By viewing and agreeing to this Policy you will be deemed to have acknowledged that Liquidus will not be held responsible for data collected of you via any link posted within this Policy, or, by any other means, to any other third-party website or service provider utilizing our platform.
OUR DISCLOSURE OBLIGATIONS
You should be aware that there may be certain rare instances where we will be obligated to disclose your data without your consent. For example, as per Section 13 of the DPA, disclosure is permitted where:
- It is necessary, in the opinion of the Minister of National Security, to safeguard the security of The Bahamas;
- It is necessary to prevent or detect an offence;
- It is necessary for the purpose of apprehending or prosecuting offenders;
- It is necessary for assessing or collecting any tax, duty or other moneys owed to the government;
- It is necessary to protect international relations;
- It is urgently necessary in order to prevent injury, death, or loss or damage to property; and,
- It is required by or under any enactment or by a rule of law or order of a court.
YOUR DATA PROTECTION RIGHTS UNDER BAHAMIAN LAW
Under the DPA, you, as the ‘data subject’, are afforded the following rights:
- That your data be collected by fair and lawful means;
- That your data be kept accurate and up-to-date;
- That your data be kept only for a specified and lawful purpose or purposes;
- That your data should not be used or disclosed in incompatible with those purposes;
- That the data collected on you should be adequate, relevant and not excessive;
- That your data should not be kept longer than is necessary for that purpose or purposes;
- That appropriate security measures should be taken against any unauthorised access to or alteration, disclosure or destruction of, your data and against its accidental loss or destruction;
- Access to data (subject to any exceptions in the statute) and/or the right to file a complaint regarding the same after a written request;
- Having your data corrected or erased if data where appropriate;
- Opting-out of direct marketing if your data was held for that purpose.
The above list is not exhaustive and, in some cases, are subject to any disclosure obligations as mentioned in the section above.
Liquidus does not knowingly request information from, or market or target children through marketing or communication under the age of 13. Please verify your age whenever prompted to do so. Should you be aware that data has been collected from a child under the age of 13 please see the ‘How to contact us with an inquiry, access request or complaint’ section of this Policy and we will remediate accordingly. If you are under the age of 13 and are not accompanied by a parent or legal guardian, please click [this link] to leave the website.
Under the GDPR, if you are an EU citizen, you enjoy the following data protection rights:
- Right of access to your data – this means that you can request to receive copies of the data we hold on you;
- Right of rectification or correction of data – this means that you can request to have your data corrected if you believe that it may be inaccurate;
- Right to erasure of your data – this means that you have the right to have your data erased subject to satisfying certain conditions;
- Right to restrict processing – this means that your have the right to request that we restrict the processing of your data subject to satisfying certain conditions;
- Right to data portability – you have the right to have your data transferred to another organisation subject to satisfying certain conditions;
- Right to object to your data being processed – this means that you have the right to request that we halt the processing of your data subject to satisfying certain conditions;
- Right to withdraw of consent – this means that you have the right to opt-out of any product, service or communication that you receive by us subject to satisfying certain conditions;
The list above is not exhaustive. If you are an EU citizen, should you proceed to view and/or use our website, mobile app or broader platform and services you will be deemed to have a full understanding of your rights contained within the GDPR. If you are not familiar with those rights, you can view them prior to proceeding with this website by clicking [this link]. If you would like to submit a data access request pursuant to these provisions please see the ‘How to contact us with an inquiry, access request, or complaint’ section of this Policy to learn how to do so.
SALE OR BANKRUPTCY
In the event that our business reorganizes, is sold, merges with another company or is acquired by another entity, the data we have collected on you may also transfer to the new entity. However, if our business is sold or enters bankruptcy, your data will be deleted from the storage disk on live and backup sites.
By viewing and agreeing this Policy you, the website visitor or app user, acknowledge that Liquidus will not be held responsible for any failure or delay in responding to or carrying out any data access request or service we provide, or for any loss or damage arising from the same, where the failure or delay is caused by reason of circumstances beyond our control (a “Force Majeure Event”). A Force Majeure Event would include, but is not limited to a: hurricane, earthquake, violent political unrest, technological breakdown, flood, fire, explosion, earthquake, terrorist acts, acts of government or of any regulatory authority or agency, and, lack of communication or power supply, etc. We reserve the right to suspend tending to any data access requests far as long as a Force Majeure Event affects our ability to provide you with a full written response or the data requested. We will only notify those individuals who have consented to provide us with their e-mail addresses of the commencement or cessation of a Force Majeure Event.
If you have signed up for an account with us, you may review or modify information pertaining to your account, or terminate your account with us altogether by accessing your account settings and clicking ‘delete my account’ or by e-mailing us a request to delete your account. Once completed, your information will be removed from our active databases.
HOW TO CONTACT US WITH AN INQUIRY, ACCESS REQUEST, OR COMPLAINT
At Liquidus we take your data privacy concerns seriously. Should you wish to:
- Terminate your account with us;
- Ask for further information in connection with this Policy;
- Request a copy of the data we hold on you;
- Complain about the way we collect, handle or process your data; or
- Exercise your data protection rights in any way.
For more information please contact us at email@example.com and your submission will be dealt with in a timely manner:
Address: Templeton House, 2nd Floor, PO Box CB12265, Nassau, The Bahamas]
HOW TO CONTACT THE RELEVANT AUTHORITIES
If you are not satisfied with the way in which your request or complaint has been addressed, you can inform the relevant data protection authority who will provide you with further guidance subject to the credibility of the complaint.
Generally, you have the option to lodge a complaint with the Data Protection Commissioner via its Government web portal [click here], e-mail (firstname.lastname@example.org), or in writing to the following address:
Office of the Data Protection Commissioner
Cecil Wallace-Whitfield Centre
West Bay Street
P.O. Box N-3017
Nassau, New Providence, The Bahamas
If you are an EU citizen, you also have the option to file a complaint under the GDPR with your local data protection authority who will make further inquiries and provide additional guidance in accordance with the Regulation. This institution will vary Member State to Member State. Click this link for a list of all of the EU Data Protection Authorities.
PRIVACY POLICIES OF OTHER WEBPAGES