Privacy Policy

1. Introduction

Welcome to Liminal ("we," "our," or "us"). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website (liminal.cash and becomeliminal.com) and our services.

Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the site or use our services.

2. Information We Collect

Personal Information You Provide

We collect personal information that you voluntarily provide to us when you:

• Register for an account
• Complete our onboarding process
• Use our financial services
• Contact us for support
• Subscribe to our marketing communications

This information includes:

• Name and contact information (email address, phone number, address)
• Identity verification documents (passport, driver's licence, visa status)
• Financial information (bank account details, transaction history)
• Employment and education information
• Date of birth and nationality

Information Automatically Collected

When you visit our website or use our services, we automatically collect certain information, including:

• Device information (IP address, browser type, operating system)
• Usage data (pages visited, time spent, click patterns)
• Location data (country, city, timezone)
• Cookies and similar tracking technologies

3. How We Use Your Information

We use the information we collect to:

• Provide, operate, and maintain our services
• Verify your identity and comply with Know Your Customer (KYC) requirements
• Process transactions and manage your account
• Prevent fraud and enhance security
• Comply with legal and regulatory obligations
• Communicate with you about updates, security alerts, and support
• Send marketing communications (with your consent)
• Improve our services and develop new features
• Analyse usage patterns and optimise user experience

4. Legal Basis for Processing

We process your personal information based on the following legal grounds:

• Contract: To fulfil our contractual obligations to you
• Legal Obligation: To comply with anti-money laundering, counter-terrorist financing, and other regulatory requirements
• Legitimate Interests: To operate our business, prevent fraud, and ensure network security
• Consent: For marketing communications and certain data processing activities

5. Data Sharing and Disclosure

We may share your information with:

Service Providers

• Identity verification services (Sumsub)
• Payment processors and banking partners
• Cloud storage and hosting providers
• Customer support tools
• Analytics and monitoring services

Legal and Regulatory

• Law enforcement agencies when required by law
• Regulatory authorities for compliance purposes
• Courts and legal proceedings when necessary

Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections.

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

6. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place for international transfers, including:

• Standard Contractual Clauses approved by regulatory authorities
• Adequacy decisions where applicable
• Ensuring recipients maintain appropriate security measures

7. Data Retention

We retain your personal information for as long as necessary to fulfil the purposes outlined in this privacy policy, unless a longer retention period is required by law. Specifically:

• Account information: For the duration of your account plus 7 years after closure
• Transaction records: 7 years as required by financial regulations
• Identity verification documents: 7 years after account closure
• Marketing preferences: Until you withdraw consent
• Technical logs: 2 years for security and debugging purposes

8. Data Security

We implement appropriate technical and organisational measures to protect your personal information, including:

• Encryption of data in transit and at rest
• Regular security assessments and penetration testing
• Access controls and authentication mechanisms
• Employee training on data protection
• Incident response procedures

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.

9. Your Rights

Depending on your location, you may have the following rights regarding your personal information:

• Access: Request a copy of your personal information
• Rectification: Correct inaccurate or incomplete information
• Erasure: Request deletion of your information (subject to legal obligations)
• Restriction: Limit processing of your information
• Portability: Receive your data in a structured, machine-readable format
• Objection: Object to certain processing activities
• Withdraw Consent: Where processing is based on consent

To exercise these rights, please contact us at support@liminal.cash. We will respond to your request within 30 days, subject to verification of your identity.

10. Cookies and Tracking

We use cookies and similar tracking technologies to enhance your experience. For detailed information about our cookie usage, please see our Cookie Policy.

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may impact the functionality of our services.

11. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

12. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before providing any personal information.

13. Updates to This Policy

We may update this privacy policy from time to time. We will notify you of any material changes by posting the new privacy policy on this page and updating the "Last updated" date. For significant changes, we will provide additional notice via email or through our services.

14. Contact Information

If you have questions or concerns about this privacy policy or our data practices, please contact us at:

For GDPR-related inquiries or to file a complaint, you may also contact your local data protection authority.