1. Introduction
Liberu Services Ltd ("we," "our," or "us") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, process, and protect your information when you use our website, software applications, and services (collectively, the "Services").
This Privacy Policy complies with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
2. Data Controller Information
3. Information We Collect
3.1 Personal Information You Provide
- Account Information: Name, email address, phone number, company details
- Billing Information: Payment details, billing address, VAT number
- Profile Information: Job title, department, preferences, profile picture
- Communication Data: Messages, support tickets, feedback, survey responses
- Business Data: Information you input into our systems for business purposes
3.2 Information We Collect Automatically
- Usage Data: How you interact with our Services, features used, time spent
- Device Information: IP address, browser type, operating system, device identifiers
- Log Data: Access times, pages viewed, errors encountered, referral sources
- Cookies and Tracking: As described in our Cookie Policy
3.3 Information from Third Parties
- Integration Data: Information from third-party services you connect to our platform
- Public Sources: Publicly available business information to enhance our services
- Partners: Information from our business partners with your consent
4. Legal Basis for Processing
We process your personal data based on the following legal grounds:
4.1 Contract Performance
- Providing our Services to you
- Managing your account and subscriptions
- Processing payments and billing
4.2 Legitimate Interests
- Improving our Services and user experience
- Security and fraud prevention
- Marketing our services to existing customers
- Business analytics and reporting
4.3 Legal Compliance
- Complying with legal obligations
- Responding to legal requests
- Maintaining records as required by law
4.4 Consent
- Marketing communications (where required)
- Optional features and services
- Cookies and tracking (where required)
5. How We Use Your Information
5.1 Service Provision
- Creating and managing your account
- Providing access to our software and services
- Processing transactions and billing
- Providing customer support
- Sending service-related communications
5.2 Service Improvement
- Analyzing usage patterns and trends
- Developing new features and services
- Conducting research and analytics
- Testing and quality assurance
5.3 Communication
- Responding to your inquiries
- Sending important service updates
- Marketing our services (with consent)
- Conducting surveys and feedback collection
5.4 Security and Compliance
- Protecting against fraud and abuse
- Ensuring system security and integrity
- Complying with legal obligations
- Enforcing our Terms of Service
6. Information Sharing and Disclosure
6.1 We Do Not Sell Your Data
We do not sell, rent, or trade your personal information to third parties for their marketing purposes.
6.2 Service Providers
We may share your information with trusted third-party service providers who assist us in:
- Cloud hosting and infrastructure
- Payment processing
- Email and communication services
- Analytics and monitoring
- Customer support tools
6.3 Legal Requirements
We may disclose your information when required by law or to:
- Comply with legal processes
- Respond to government requests
- Protect our rights and property
- Ensure user safety and security
6.4 Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the transaction.
7. Data Security
7.1 Security Measures
We implement appropriate technical and organizational measures to protect your data:
- Encryption in transit and at rest
- Access controls and authentication
- Regular security assessments
- Employee training and confidentiality agreements
- Incident response procedures
7.2 Data Breach Notification
In the event of a data breach, we will:
- Notify relevant authorities within 72 hours
- Inform affected users without undue delay
- Take immediate steps to contain and remedy the breach
8. Data Retention
8.1 Retention Periods
We retain your personal data for as long as necessary to:
- Provide our Services to you
- Comply with legal obligations
- Resolve disputes and enforce agreements
- Fulfill legitimate business purposes
8.2 Deletion
When data is no longer needed, we will:
- Securely delete or anonymize the information
- Ensure complete removal from our systems
- Maintain records of deletion where required
9. International Data Transfers
9.1 Transfer Safeguards
When we transfer your data outside the UK/EEA, we ensure adequate protection through:
- Adequacy decisions by the UK government
- Standard Contractual Clauses (SCCs)
- Binding Corporate Rules
- Other approved transfer mechanisms
9.2 Third Country Processing
Some of our service providers may process data in countries outside the UK/EEA. We ensure these transfers comply with UK GDPR requirements.
10. Your Rights
Under UK GDPR, you have the following rights:
10.1 Access Rights
- Request access to your personal data
- Obtain a copy of your data we hold
- Understand how we process your information
10.2 Correction and Completion
- Correct inaccurate personal data
- Complete incomplete personal data
- Update your information
10.3 Erasure ("Right to be Forgotten")
- Request deletion of your personal data
- Subject to legal and contractual obligations
- May affect service provision
10.4 Restriction of Processing
- Limit how we process your data
- Temporary suspension of processing
- While disputes are resolved
10.5 Data Portability
- Receive your data in a structured format
- Transfer data to another service provider
- Where technically feasible
10.6 Objection
- Object to processing based on legitimate interests
- Object to direct marketing
- Object to automated decision-making
10.7 Withdrawal of Consent
- Withdraw consent at any time
- Does not affect prior lawful processing
- May impact service provision
11. Exercising Your Rights
To exercise your rights, please contact us at:
- Email: privacy@liberu.co.uk
- Subject Line: "Data Protection Request"
- Include: Your name, account details, and specific request
We will respond to your request within one month, or inform you if we need additional time.
12. Cookies and Tracking
12.1 Cookie Usage
We use cookies and similar technologies to:
- Ensure proper functioning of our Services
- Remember your preferences and settings
- Analyze usage and improve performance
- Provide personalized experiences
12.2 Cookie Management
You can control cookies through:
- Browser settings and preferences
- Our cookie consent management tool
- Opt-out mechanisms where available
For detailed information, please see our separate Cookie Policy.
13. Children's Privacy
Our Services are not intended for children under 16. We do not knowingly collect personal information from children under 16. If we become aware of such collection, we will delete the information immediately.
14. Marketing Communications
14.1 Consent
We will only send marketing communications with your consent or where we have a legitimate interest (for existing customers).
14.2 Unsubscribe
You can unsubscribe from marketing communications at any time by:
- Clicking the unsubscribe link in emails
- Updating your account preferences
- Contacting us directly
15. Automated Decision-Making
15.1 Automated Processing
We may use automated processing for:
- Fraud detection and prevention
- Service personalization
- System security monitoring
15.2 Your Rights
You have the right to:
- Request human intervention
- Express your point of view
- Contest automated decisions
16. Third-Party Links
Our Services may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. Please review their privacy policies before providing any information.
17. Updates to This Policy
17.1 Policy Changes
We may update this Privacy Policy to reflect:
- Changes in our practices
- Legal or regulatory requirements
- Service improvements
17.2 Notification
We will notify you of material changes by:
- Email notification
- Prominent notice on our website
- In-app notifications
18. Complaints and Concerns
18.1 Contact Us
If you have concerns about our privacy practices, please contact us first at privacy@liberu.co.uk.
18.2 Regulatory Authority
You have the right to lodge a complaint with the Information Commissioner's Office (ICO):
Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Phone: 0303 123 1113
Website: https://ico.org.uk
19. Contact Information
For any questions about this Privacy Policy or our data practices, please contact us:
Data Protection Officer
Liberu Services Ltd
85 Great Portland Street, First Floor
London, United Kingdom, W1W 7LT
Email: privacy@liberu.co.uk
Phone: As provided on our website
This Privacy Policy is effective as of the date last updated above.