December 13, 2023
- “Non-Personal Information” means Information which does not personally identify a person.
- “Personal Information” means information related to a natural person that can be used to directly or indirectly identify the person, such as names, addresses, e-mail addresses, and phone numbers, as well as other non-public information that is associated with the foregoing.
2. Acceptance of Terms
3. Information We Collect and How We Collect It
3.1 Information You Provide. We collect your Personal Information when you create or update your Liquid account, submit information when using the Site or Services, submit information to verify your identity, contact us with questions or feedback, participate in a market research program, contest or survey, or otherwise communicate with us. This Personal Information may include your name, mailing address, location information, email address, phone number, bank account/credit card information and taxpayer identification number. In addition, please be aware that if you enable those features on our Platform that allow you to share your User Content with others, anyone you have shared content with (including the general public, in certain circumstances) may have access to your User Content.
3.2 Your Email or Social Network Contacts. We collect your email, social network, and other contacts (“Contacts”) if you choose to share them with us, or if you choose to refer potential customers to us via our referral programs (the “Referred Leads”).
3.3 Public Information. We may collect information about you from public sources, such as public social media pages.
3.4 Information from Third Parties. We may collect information about you, including personal information and financial account information, from third parties, such as financial institutions and our service providers, for purposes of identity verification, fraud protection, risk assessment, and other purposes. We may collect your business information from credit bureaus for the foregoing purposes as well. We may also collect information about you from other users naming you as a Referred Lead or from users requesting that you be added to the Services as a “worker”. In addition, we may receive demographic information about you from third parties to help us better understand our users and to improve and market our Services.
3.5 Automatically Collected Information. As is true with most service providers, we may automatically collect certain usage information when you access the Site or use the Services, such as your device identifier (if using a mobile device), Internet Protocol (IP) address (if using a browser), operating system, browser type and version, time zone setting, Internet service provider (ISP), referring and exit websites and applications, and clickstream data. We use this information to understand and analyze trends, to administer the Site, to learn about user behavior on the Site, to improve our products and services, and to gather demographic information about our users. We may also use this information in our marketing and advertising services. We also automatically collect certain usage information through cookies and related technologies, as described in Section 3.7 below. In addition, our Site may implement third-party software, such as Google’s Invisible reCAPTCHA, that collects your information for security purposes.
3.6 Single Sign-On Information. Single Sign-On allows you to sign in to the Services from another service you use and with which we partner. We will collect certain information for security purposes to verify your authorized access to the Services, including your username and password for the other service.
3.7 Cookies and Other Related Technologies.
3.7.1 Cookies are small pieces of text placed on your browser by websites that you visit. When you use or access the Site, we may place a number of cookies files in your web browser, which allow the Site to recognize you, to make the website function properly, and to collect data about you and your usage, as well as to provide business and marketing information to us. By using or accessing our Site, you agree that we may use, store, and access cookies on and from your computer or other device and that we may use additional methods to collect website usage data and IP addresses.
3.7.3 Pixel tags enable email messages in a format that customers can read, and they indicate whether email has been opened. We may also use this information to reduce or eliminate messages sent to you.
3.7.4 Most Internet browsers let you change the browser’s settings to stop accepting cookies or to prompt you before accepting a cookie from websites you visit. For more information on how to manage cookies, visit your browser’s help pages. If you do not allow cookies, you may not be able to use some or all portions or functionality of the Site or Services. Please note that if you change computers or web browsers, you will need to disable cookies once again.
4. Use of Your Information
4.1 We use information that we collect about you for the following purposes:
- to administer the Site, manage accounts and provide the Services;
- to monitor, analyze, improve and develop content, advertising and the Site and Services, and to create new features of the Services;
- to provide a more customized experience on the Site, Services and/or our partners’ or affiliates’ websites;
- to verify identity and determine appropriate services;
- to understand our users better;
- to validate user information provided to us for fraud and risk detection purposes;
- to determine eligibility for the Services;
- for internal purposes such as auditing, data analysis, and research;
- to prevent, identify and address fraudulent or other illegal activity and security issues;
- to (i) solicit feedback, (ii) respond to your comments, requests or inquiries, (iii) provide customer service and support, or (iv) otherwise contact you in connection with the Site or Services;
- to generate anonymized, aggregate data containing only de-identified, non-personal information that we may use to publish reports;
- for our marketing purposes, such as (i) informing you of our or our partners’ or affiliates’ products, services, features or offerings that may be of interest to you, (ii) providing you with newsletters, articles, reports, updates and announcements, as well as information about upcoming events, (iii) contacting Referred Leads and suggesting Contacts for you to refer to Liquid, (iv) improving and tailoring our advertising and communications, (v) analyzing our marketing efforts, and (vi) determining your eligibility for certain marketing programs, events and offers. If you prefer to be removed from our mailing list, you can opt-out at any time by updating your preferences in your account or contacting us at firstname.lastname@example.org;
- to operate our business, which includes, without limitation, using your information (i) to process payments, (ii) to send important notices, such as communications regarding the Site and Services, and changes to our terms and policies; (iii) to manage and enforce contracts with you or with third parties, (iv) to manage our corporate governance, compliance and auditing practices, and (v) for recruitment purposes, if you submit an application for employment with Liquid via the Site;
- to administer any sweepstakes, contests, or similar promotions you may enter;
- in the case of non-personal information (which includes, without limitation, zip code, area code, unique device identifier, referrer URL, location, and the time zone), we may collect, use, transfer, and disclose non-personal information for any purpose;
- to (i) comply with laws, rules and regulations, including any disclosure or reporting obligations, (ii) resolve disputes with users or third parties, (iii) respond to claims and legal process (including but not limited to subpoenas and court orders) as we deem necessary or appropriate, (iv) protect our property rights or those of third parties, (v) protect the safety of the public or any person, and (vi) prevent or stop any activity which we may consider to be (or to pose a risk of being) illegal, unethical or legally actionable; and
- for any other purpose for which you expressly authorize us to use your information.
5. Disclosure to Third Parties
5.1 We will share your information only with the third parties listed below for the purposes described above in Section 4 - “Use of Your Information”:
- government agencies and taxing authorities, as required to provide the Services, including but not limited to the Internal Revenue Service and state and local tax agencies;
- banking and financial institutions;
- certain parties as necessary to respond in good faith to legal process (including but not limited to subpoenas and court orders);
- legal and financial advisors and auditors;
- third-party agents, partners and service providers, who (i) are only permitted to use your information as we allow (which may include contacting you on our behalf), and (ii) are required under law or contract to keep your per sonal information confidential; and
- the following third parties under the circumstances described below:
- we may share business information with credit bureaus, and we may share information with certain companies, banks and organizations for the purposes of fraud prevention and determining eligibility for the Services;
- if you participate in our referral programs and/or share your Contacts with us and invite them to join Liquid, the referral emails sent to your Contacts and Referred Leads will include your name and the fact that you are a Liquid user;
- if there is a sale of all or a portion of the Liquid business (including, without limitation, a merger, stock acquisition, sale of assets or reorganization), or in the event that Liquid liquidates or dissolves, we may sell, transfer or otherwise share some or all of our assets, which could include your information, to the acquirer;
- from time to time, we may share reports with the public that contain anonymized, aggregate, de-identified information and statistics;
- we may share your information with certain other third parties with whom you expressly authorize us to share your information; and
- we may disclose information about you if we determine that for purposes of national security, law enforcement or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users.
5.2 We do not share information with third parties for their own direct marketing purposes.
6. Protection of Personal Information
6.1 We take the security of your personal information very seriously. We protect your personal information during transit using encryption such as Transport Layer Security (TLS). When your personal data is stored by us, we use computer systems with limited access housed in facilities using physical security measures. All data stored in the cloud is maintained in encrypted form, including when we utilize third-party storage providers.
6.2 Although we have put in place commercially reasonable protections and procedures to safeguard and secure the Personal Information we collect. even with these measures, we cannot guarantee the security of Personal Information. By using our Services or our Site, you acknowledge and agree that we make no such guaranty.
6.3 When using the Site or Services, you may be provided the opportunity to post in a forum or chat room. Should you choose to do so, note that the personal information and content you share is visible to other users and can be read, collected or used by them. You are responsible for the personal information you choose to communicate in these instances.
7. Access to Your Personal Information
You may review, update, correct or delete your personal information through your account or by contacting us using the contact information listed below. We will provide you with access to your personal information for any purpose, including to request that we correct the data if it is inaccurate or delete the data if we are not required to retain it by law or for legitimate business purposes. If you would like us to delete your account entirely, please contact us at email@example.com with a request that we delete your account and personal information. We may retain some of your personal information as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, or as needed for other legitimate business purposes. Additionally, we may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by applicable law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes as previously described.
8. Retention of Personal Information
9. Legal Bases for Our Use of Your Personal Information
9.1 We rely on both your consent and our legitimate business interests as the legal bases for processing Personal Information. In this regard, we use your Personal Information when necessary (a) to perform our obligations under any contract with you; (b) to comply with our legal obligations (for example, complying with our legal and regulatory obligations); and (c) for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our Site or Services). If we rely on our (or another person's) legitimate interests for using your Personal Information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the Personal Information.
9.2 If we rely on your consent for us to use your Personal Information in a particular way, but you later change your mind, you may withdraw your consent by contacting us at the e-mail address set forth in the “Contact Us” section below, and we will stop doing so.
10. Links to Other Sites
11. Notice for Minors
11.1 Children under the age of 13 are not permitted to create an account with Liquid or use the Services, and we do not knowingly collect personal information from children under 13. If you believe that we may have collected personal information from a child under 13, please notify us at firstname.lastname@example.org and we will investigate and promptly address the issue. If we learn that we have collected the personal information of a child under 13, we will take steps to delete the information as soon as possible.
11.2 Minors, or their legal guardians, may change or revoke the consent choices previously made or request access to or removal of any personal information that they have provided or posted to a Liquid forum or chat room by contacting us at email@example.com. Within thirty days of such a request (unless another period is provided by law), we will anonymize or remove from public view such information unless we are legally required to retain such information. You should be aware that the removal of content may not ensure complete or comprehensive removal of that content or information posted through the services.
12. Your California Privacy Rights
12.1 Under California Civil Code Section 1798.83, California residents are entitled once per year to request certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes during the preceding calendar year. We do not share our customer’s personal information with third parties for their own direct marketing purposes. California residents may request further information about our compliance with this law by sending a request to the address set forth in the Contact Information section below. You must include “California Privacy Rights” in the subject line, and your full name, email address and postal address in your request. We will be happy to respond to your request.
12.2 If you are a California resident under the age of 18 and a registered user, you can request that we remove content or information that you have posted to our Site or Services. Note that fulfilment of the request may not ensure complete or comprehensive removal (e.g., if the content or information has been reposted by another user). To request removal of content or information, please email us at firstname.lastname@example.org.
14. Contact Us