Privacy Policy

Effective Date: 2020-01-01

Liqural Limited (“we” or “us”) take the privacy of your information very seriously. This notice is designed to tell you about our practices regarding the collection, use and disclosure of personal information which may be collected in person from you, obtained via our website www.liqural.com, app or collected through other means such as by an online form, email, or telephone communication.

This notice applies to personal information provided by our clients, where applicable their staff and any third party suppliers whose data we process, but does not apply to information we hold in relation to our staff or contractors. In this notice “you” refers to any individual whose personal data we hold or process. This privacy notice is governed by the EU GeneralData Protection Regulation (the “GDPR”), the Data Protection Act 2018 and any other applicable data or privacy legislation.

In general our services relate to the offering of modelling, forecasting and quantitative analysis services whereby Subscribers are able to view predictions according to the specific items they have signed up to.

By using the services, you agree to the collection and use of information in accordance with this notice.

This notice may be updated from time to time and you should check this page regularly for any updates. Changes to this notice are effective when they are posted on this page.

Personal data we collect and how we process this data

Below we have set out the categories of data we collect, the legal basis we rely on to process the data and how we process the data:

• Contact information for our users who have registered with us such as name, email address, address, telephone number (for authentication) or other log-in details (“Contact Information”). We process this information to provide our services and communicate with you (including with respect to customer care and support) on the basis of performing our contract with you or on the basis of our legitimate interest in providing our services to our clients.
• Contact information which we hold because you are a third party relevant to the services we provide to our clients (you may for example be a payment processor, marketing software provider, credit agency or professional advisor such as a lawyer or accountant) (“Third Party Contact Information”). We process this information when we provide services to our clients on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to our clients.
• Financial information which we hold in the context of providing services to our clients (“Financial Information”) such as billing and banking details. We process this information when we provide services to our clients on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to our clients.
• Marketing information. We may hold information about you in order to provide information about our services. This may include names, job titles, email addresses, phone numbers, addresses, and other information (“Marketing Information”). We process this information in order to improve or communicate with you about our products and services, for market research purposes or in order to customise our services, on the basis of our legitimate interests in communicating with you about our services or on the basis that you have consented to receiving the information.
• Cookie Information. A cookie is a small text file which asks permission to be placed on your computer’s hard drive or mobile device. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. We process Cookie Information in order to improve or communicate with you about services and/or to customize the website according to your personal interests, on the basis (where applicable and necessary) that you have consented to this.
• A record of any correspondence or communication between you and us (“Communication Information”). We process this information when we monitor our relationship with you and provide services to you on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to our clients.

We will collect information either from you directly or from a third party (for instance an introducer). If we do obtain your personal data from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this privacy notice.

Data Retention

Our current data retention policy is to delete or destroy (to the extent we are able to) personal data after the following periods:

• Records relating to a contract with us - 7 years from either the end of the contract or the date you last used our services or placed an order with us, being the length of time following a breach of contract in which a contract party is entitled to make a legal claim.
• Marketing records - 3 years from the last date on which you have interacted with us.

For any category of personal data not specifically defined in this section or notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data. The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).

We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or securely delete this data as may be required.

If you wish to request that data we hold about you is amended or deleted, please see below for your privacy rights.

Sharing your information

We may disclose information to third parties in the following circumstances:

• We may work with other professionals and providers in providing and delivering our services to you, this may include a payment processor, marketing software provider, credit agency or professional advisor such as a lawyer or accountant;
• We may disclose information to our group companies (as applicable);
• If we are sub-contracting services to a third party we may provide information to that third party in order to provide the relevant services;
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
• In order to enforce any terms and conditions or agreements for our services that may apply;
• As part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganization, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;
• To protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that such third party complies with the terms of this notice.

Cookies and IP Address

Like most websites and applications, we use cookies to help provide you with the best experience whilst using our service. The cookies we use are split between the following categories:

• Strictly necessary cookies - which are an essential part of our service and affect the way you can use our site (e.g. security & authentication)
• Performance cookies - which are used for analytics (e.g. understanding usage on our website)

On your first visit to our site from your browser we will display a notice to notify you that we are using cookies but we will not load any cookies, except for Strictly Necessary Cookies, until you have provided your consent by clicking the “Accept” button. If you click the “Accept” button on our cookies notice, Performance cookies will also be loaded.

As well as cookies that are set by domains we control (first-party cookies), you may also see cookies set by a third party (third-party cookies). These are set when you interact with certain parts of our service and are used by these third-party services to understand your preferences and sometimes tailor content they show you.

Refusing Cookies

You can change the way your browser handles cookies if you wish. You could accept or reject them by default or be notified when a website is trying to set or update cookie. Exactly how you disable cookies depends on the browser or device you are using. The help feature on most browsers will tell you how you how you can manage and or disable cookies. If you disable cookies on your browser, certain features or parts of our service may not function correctly or will have a degraded experience.

Tracking and Analytics Cookies

We use analytic tools, such as Azure Application Insights and Google Analytics to understand how our site is used and where we can make improvements to provide you with the best experience.

If you choose not to accept the cookies, this will not affect your access to the majority of information available on the service. However, you will not be able to make full use of our online services.

An Internet Protocol (IP) address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the Internet. We may use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our service, and to administer and improve the online service.

Security

We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):

• protecting our servers by both hardware and software firewalls;
• We may disclose information to our group companies (as applicable);
• encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
• when necessary, disposing of or deleting your data so it is done so securely;
• regularly backing up and encrypting all data we hold.

We will ensure that our staff are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and data security obligations.

This notice and our procedures for handling personal data will be reviewed as necessary.

Third party links

Our website may contain links to other sites that are not operated by us. This notice applies to our services only so if you click on a third-party link, we strongly advise you to review that site’s privacy policy.

We have no control over and are not responsible or liable for the content, privacy policies or practices of any third-party sites or services.

With respect to your personal data, you have:

• The right to be informed - i.e. a right to know about our personal data protection and data processing activities, details of which are contained in this notice
• The right to access - the right to request a copy of any personal data that we have about you
• The right to rectification - the right to request a correction of any errors in or update of the personal data that we have about you
• The right to erasure (the ‘right to be forgotten’) –the right to request that your personal data is deleted from our records;
• The right to restrict processing – the right to request that we no longer process your personal data in certain ways, whilst not requiring us to the delete the same data;
• The right to object to processing – the right to request that your personal data will not be processed;
• The right to data portability - the right to request that your personal data be transferred or exported to another organisation
• The right to withdraw consent – at any time, you have the right to withdraw any permission you have given us to process your personal data
• Rights in relation to automated decision making and profiling
  - The right not to be subject to automated decision-making (including profiling) when those decisions have a legal (or similarly significant effect) on you
  - The right to request that your personal data will not be used to contact you for direct marketing purposes

All SARs and other requests or notifications in respect of your above rights must be sent to us in writing at info@liqural.com or by post to Raza Hassan, Liqural Limited, 118, 681 Commercial Road, London, United Kingdom, E14 7LH.

We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).

Data breaches

If personal data we hold about you is subject to a breach or unauthorized disclosure or access, we will report this to our data protection manager or officer (if an officer has been appointed) and the Information Commissioner’s Office (ICO) (as necessary).

If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.