Privacy Policy

This privacy notice for Liberty91 LTD (‘we’, ‘us’, or ‘our’), describes how and why we might collect, store, use, and/or share (‘process’) your information when you use our services (‘Services’), such as when you:

• Visit our website at https://liberty91.com, or any website of ours that links to this privacy notice
• Download and use our mobile application (Liberty91), or any other application of ours that links to this privacy notice
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at contact@liberty91.com.

Summary of Key Points

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

How do we keep your information safe? We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us at contact@liberty91.com. We will consider and act upon any request in accordance with applicable data protection laws.

1. What Information Do We Collect?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

The personal information we collect may include the following: names, email addresses, usernames, passwords, contact preferences, and company.

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by Stripe.

Application Data.If you use our application(s), we also may collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out, you may turn them off in your device's settings.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information.

The information we collect includes:

• Log and Usage Data. Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services.
• Device Data. Information about your computer, phone, tablet, or other device you use to access the Services.
• Location Data.Information about your device's location, which can be either precise or imprecise. You can opt out of allowing us to collect this information by disabling your Location setting on your device.

2. How Do We Process Your Information?

We process your personal information for a variety of reasons, including:

• To facilitate account creation and authentication and manage user accounts
• To deliver and facilitate delivery of services to the user
• To respond to user inquiries and offer support
• To send administrative information about our products and services
• To request feedback about your use of our Services
• To protect our Services, including fraud monitoring and prevention
• To identify usage trends and improve our Services
• To determine the effectiveness of our marketing and promotional campaigns
• To save or protect an individual's vital interest

3. What Legal Bases Do We Rely On to Process Your Information?

If you are located in the EU or UK

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on to process your personal information. We may rely on the following:

• Consent. You have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We believe it is necessary to fulfil our contractual obligations to you.
• Legitimate Interests. We believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your rights and freedoms.
• Legal Obligations. We believe it is necessary for compliance with our legal obligations.
• Vital Interests. We believe it is necessary to protect your vital interests or those of a third party.

If you are located in Canada

We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.

4. When and With Whom Do We Share Your Personal Information?

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. How Long Do We Keep Your Information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law. No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible, securely store your personal information and isolate it from any further processing until deletion is possible.

6. How Do We Keep Your Information Safe?

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

7. Do We Collect Information from Minors?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at contact@liberty91.com.

8. What Are Your Privacy Rights?

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right to request access and obtain a copy of your personal information, to request rectification or erasure, to restrict the processing of your personal information, if applicable to data portability, and not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us at contact@liberty91.com.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us.

Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can contact us. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases.

9. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems include a Do-Not-Track (‘DNT’) feature or setting. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

10. Do California Residents Have Specific Privacy Rights?

Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information. California Civil Code Section 1798.83, also known as the ‘Shine The Light’ law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your rights under the CCPA include:

• Right to request deletion of your data
• Right to be informed whether we collect and use your personal information
• Right to non-discrimination for exercising your privacy rights

To exercise these rights, contact us at contact@liberty91.com.

11. Do Virginia Residents Have Specific Privacy Rights?

Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information under the Virginia Consumer Data Protection Act (CDPA). These include the right to be informed, access, correct, delete, and obtain a copy of your personal data, as well as the right to opt out of targeted advertising, sale of personal data, or profiling.

We have not sold any personal data to third parties for business or commercial purposes. Contact us at contact@liberty91.com to exercise your rights.

12. Do We Make Updates to This Notice?

We may update this privacy notice from time to time. The updated version will be indicated by an updated ‘Revised’ date and will be effective as soon as it is accessible. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

13. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at contact@liberty91.com or contact us by post at:

Liberty91 LTD
Al Sarab Tower — Al Maryah Island
Abu Dhabi Global Market Square
11th Floor, 302-D03
Abu Dhabi, United Arab Emirates

14. How Can You Review, Update, or Delete the Data We Collect from You?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us at contact@liberty91.com.