Privacy Policy

1. Purpose

Our Privacy Policy explains how Liquid Avatar Technologies Inc., Liquid Avatar Operations Inc. and Oasis Digital Studios Limited (“LIQUID AVATAR” or the “Companies”) their subsidiaries, affiliate companies and the digital on-boarding, Know-Your-Customer (KYC), Anti-Money Laundering (AML) and age verification companies that LIQUID AVATAR works with collect, use, store and disclose your personal information. It also describes the choices available to you concerning the use of, your access to, and how to update and correct your personal information.  For residents of the State of California, please see Section 16 of this policy for the related information on the California Consumer Protection Act 2018.

2. Scope

This Privacy Policy applies to personal information that LIQUID AVATAR collects when you use or access the Companies’ web and mobile applications and other Services offered by LIQUID AVATAR that mention this policy (collectively referred to as “Services”) including sites such as, but not limited to:

www.liquidavatartechnologies.com

www.liquidavatar.com

www.liquidavataroperations.com

www.oasisdigitalstudios.com

www.liquidshopz.com

www.lqidcard.com

“Personal Information” is defined as any information about an identifiable individual.

Personal information will be handled by LIQUID AVATAR in accordance with the EU General Data Protection Regulation and the UK GDPR (collectively “GDPR”), the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and this Privacy Policy.

3. Consent

When you sign up for a user account, LIQUID AVATAR will ask you to provide the necessary personal information required under the lawful basis of performance of a contract in order for LIQUID AVATAR to provide you with the Services.  Such information will include specific personal information which may include ID documentation, other personal information, and a “selfie” picture of yourself. The documentation required will depend on the level of verification you request.  Additional documentation in the form of a utility bill or bank statement may be required. In the event that you no longer wish to receive the Services from LIQUID AVATAR and you provide LIQUID AVATAR with notice that you no longer wish to receive the Services, LIQUID AVATAR will at that time delete all personal information relating to you and used to provide you with the Services.

4. Security

LIQUID AVATAR takes commercially reasonable measures to help safeguard your personal information from loss, disclosure, alteration, misuse and unauthorized access, theft and destruction. This includes, when required or appropriate and feasible, obtaining written assurances from third parties that may access your data that they will protect the data with adequate safeguards. The internet is not 100% secure.  LIQUID AVATAR has no control over the security protocols for internet networks that may be used by you.  LIQUID AVATAR cannot guarantee the absolute security of your information that you choose to transmit over the internet and we do not accept liability for unintentional disclosure. LIQUID AVATAR is not responsible for the security of information that you transmit to us over networks that the Companies do not control, including the internet and wireless networks.

If you have any questions about the security of your personal information, please contact us at support@liquidavatar.com

5. Collection of Information

LIQUID AVATAR collects the following types of information:

Information that you provide to LIQUID AVATAR directly to deliver Services requested

When you use the Services to register an account with LIQUID AVATAR, the Companies will collect your information based on the Services you request.  For Proof of Humanity, the Companies will collect your complete mobile device number including country and area code, your jurisdiction of residence, your date of birth and a live “Selfie”.

When you use the Services to verify your identity through LIQUID AVATAR, in addition to the information for Proof of Humanity, the Companies will collect information such as your email address, ID Documents (passport, driver’s license, ID card, etc…), document type, scan of the document, account ID, legal name, national ID number, gender,  address, proof of address (such as a utility bill or bank statement), IP address, user name, blockchain address, email, local storage, user display settings, Google authenticators, audit logs, and device camera.

Facial Biometric Identity Verification

Facial biometric identity verification is accomplished by comparing two or more captured images of faces. The biometric identifiers used to complete this assessment are taken from the images that you submit.

We will also use your selfie image to complete an age estimation.  This is to ensure that the age information you provide to us is accurate.  This age estimation is done via Facelytics by Wasaa, a third-party service provider, however LIQUID AVATAR only sends the selfie image out for estimation with no other personal information attached.  We receive back the age estimation, and the third party service provider permanently deletes the image.

Information we may collect from Third Parties

LIQUID AVATAR may collect information about you from other sources, including third parties that help the Companies verify your eligibility for LIQUID AVATAR Services. This information may be combined with personal information that has been collected about you under this Privacy Policy. Please note that the information LIQUID AVATAR may receive from these third parties is governed by the privacy settings, policies, and/or procedures of the third parties.

6. Marketing

Users will be asked upon signing up for LIQUID AVATAR Services if they would like to receive marketing information on our various products.  Such marketing messages may be delivered to those users who choose to opt-in via personal contact such as email, SMS or by text message.  Users may change their preferences to withdraw their consent to receive these personal messages at any time.

All users of our applications or users who log into our services online will be informed of offers available to them within the app or websites.  Notifications of such offerings during use of the services are not subject to change via preference settings.

7. Cookie Policy

A cookie is a small text file that is placed and stored on your computer, mobile or other devices by webpages that you visit. The Cookies collect information in an anonymous form, including the number of visitors to the webpage, how the visitor found the webpage and recent webpages visited. All cookies used by LIQUID AVATAR are in accordance with current regulations.

Before Cookies are placed on your device, you will be shown a pop-up requesting your consent to LIQUID AVATAR’s use of Cookies. Your consent enables LIQUID AVATAR to provide the best possible service to you.

If you do not consent to the use of Cookies certain features of the LIQUID AVATAR Service may not function as intended. You are also able to delete Cookies from your device at any time.

LIQUID AVATAR uses cookies for language selection and other semi persistent settings for visitors who are not signed in. LIQUID AVATAR uses an encrypted session cookie for signed in users to identify who is signed in. Any other information in the encrypted session cookie is only available to read by our servers and should be treated as server data. It could include temporary messages or errors while using the app.

LIQUID AVATAR may also use any of the following categories of Cookies.

1. Essential Cookies

The Cookies are strictly necessary for the LIQUID AVATAR websites to function. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. These Cookies do not store any personally identifiable information.

2. Analytics Cookies

These Cookies track information about visits to the websites so that we can make improvements and report performance. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these Cookies collect is aggregated and anonymous.

3. Functional or Preference Cookies

These Cookies enable the websites to provide enhanced functionality and personalisation. They are used to remember information you have entered or choices you make (i.e. username or language) on the LIQUID AVATAR websites. They may be set by LIQUID AVATAR or by third party providers whose services we have added to our pages.

8. Use of Information

LIQUID AVATAR may use the information collected from you for the following purposes:

LIQUID AVATAR may use personal information to provide products, Services or information requested by you. Examples include: to manage your individual information and account, help you efficiently access your information after you sign in, allow access to certain functionalities and features of the Companies’ Services, and respond to your inquiries.

LIQUID AVATAR may use personal information for the following administrative purposes:

• Verify your identity
• Provide Proof of Humanity credentials
• Provide a Meta Park Pass credential
• Process applications and transactions
• Validate your identity with third parties of your choosing and upon your direction
• Transfer your information that you choose to share with third parties upon your direction
• Measure interest in LIQUID AVATAR’s Services
• Develop new products and Services or improve existing products and Services
• Monitor metrics such as total number of visitors, traffic, and demographic patterns applicable to the Services
• Send you Service-related emails (i.e., account verification, changes or updates to features of the Service, technical and security notice)
• Compliance with legal obligations and regulatory requirements (i.e., respond to legal process or request for information issued by government authorities)
• Prevent potentially prohibited or illegal activities
• Enforce LIQUID AVATAR Terms and Conditions

9. Sharing of Information

LIQUID AVATAR will not rent, share, transfer or sell your information to third parties without your consent or as agreed for the purposes of delivering the services as noted in this Privacy Policy.

LIQUID AVATAR may disclose information the Companies collect in the following circumstances or as otherwise described in this Privacy Policy:

With Vendors and Service Providers

LIQUID AVATAR may disclose your information to third party service providers that perform services on behalf of the Companies, such as web-hosting companies, analytics providers and information technology providers. LIQUID AVATAR entrusts personal information to the following types of service providers:

• Service Providers, such as vendors, consultants, IT and related services who perform certain services on behalf of LIQUID AVATAR, in which case we enter into a contract that describes the purpose of processing and requires the recipient to not use it for any purpose except performing the contract
• Third party application analytics organizations who may record via the app: Screens visited, Interaction patterns (such as screen actions, gestures: taps, scrolls) and Device details (Type, Version, Model, Operating System)
• Our affiliates, as needed to operate our business and provide services
• Customer service activities
• Fraud prevention
• Providers of services you have requested

LIQUID AVATAR has contracts with service providers that forbid them from using or disclosing personal information except as necessary to execute the contracted services on behalf of the Companies or to fulfil legal obligations.

In the event you choose to apply for a LQID Card, the issuing bank will ask you for additional information that is necessary in order to approve you for a card.  Any information provided to Community Federal Savings Bank will be subject to the bank privacy policy.  Any use by you of the LQID Card will also fall under the terms and conditions and privacy policies of Community Federal Savings Bank.

With Law Enforcement or Government Authorities

LIQUID AVATAR may disclose information as may be permitted or required by laws of any jurisdiction that may apply to the Companies, as provided for under contract, or as LIQUID AVATAR deems reasonably necessary to provide legal services. In these circumstances, the Companies take reasonable efforts to notify you prior to disclosing information that may reasonably identify you, unless prior notice is prohibited by applicable law or is not possible or reasonable in the circumstances.

Change of Control

If LIQUID AVATAR sells or otherwise transfers part or the whole of LIQUID AVATAR or the Companies’ assets to another organization (i.e., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. The buyer or transferee will have to honour the commitments LIQUID AVATAR has made in this Privacy Policy.

10. Storage of your personal information

LIQUID AVATAR uses Amazon Web Services (AWS) to store your information in order to provide it with the highest level of protection, however AWS does not necessarily have servers inside every jurisdiction.  By accepting this Privacy Policy, you provide your explicit permission to store your information on systems outside your jurisdiction only when they are not available inside your jurisdiction and to transfer that data to your jurisdiction when systems become available to do so.   

11. Transfer of Data

LIQUID AVATAR takes all reasonable steps to ensure that the data we collect under this privacy statement is processed according to the provisions of this statement and the requirements of applicable law wherever the data is located. LIQUID AVATAR operates throughout the world and although we try to store your information within your own country, this isn’t always possible and we may transfer personal data from your country to the European Economic Area or the United Kingdom (UK) and to other countries, which have been determined by the European Commission to have an adequate level of data protection.  Some of these data transfers may include a transfer between LIQUID AVATAR entities, to third party suppliers and to cloud based storage providers.

Any transfer we make is done using a variety of legal mechanisms, including contracts, to help ensure your rights and equivalent protections travel with your data. We want to ensure that data is stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) and the UK where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data.

Ways in which we safeguard your data include, but are not limited to:

1. Through the use of a transfer agreement which includes the current standard contractual clauses put in place by the European Commission for the transfer of personal data;
2. For any transfer of data to a US based entity, we require that entity to sign up to Standard Contractual Clauses with Supplementary measures as ratified by the EU and UK to safeguard data;

Other circumstances under which your data could be transferred include when it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interest for the purposes of the contract and where you have consented to the data transfer.

12. Individual’s Data Rights

We respect the rights and freedoms of individuals and as such we would like to make you aware of the following:

You have the right to:

• Request access to your data
• Request rectification of your data where there are errors or inaccuracies or the data is not current
• Request that the data we hold is removed entirely from our systems (the right to have data removed is only applicable where it does not conflict with our legal and regulatory requirements to keep certain records according to the data retention period)
• Request us to restrict processing of your data
• Object to our processing of your data
• Request your data in a format that is commonly used/accepted
• Send your data to another controller
• Withdraw consent already provided – at any time

You also have the right to complain to us.  To lodge a complaint or to exercise any of your rights listed above, please contact us at support@liquidavatar.com and direct your email to the attention of the Data Protection Officer.

In the EU or the UK, you also have the right to lodge a complaint with a supervisory authority.

13. Third Party Services and Content

The third party vendors with which LIQUID AVATAR shares your personal information are contractually required by the Companies to keep this information confidential and may generally not use such information for any purpose other than to help the Companies provide solutions to LIQUID AVATAR customers.

LIQUID AVATAR’s Services may include integrated content or links to content provided by third parties. This Privacy Policy does not address the privacy, security, or other practice of the third parties that provide such content.

LIQUID AVATAR may use third party service providers to collect personal information on its behalf.  These third party service providers may be located in countries where the privacy laws provide different levels of protection for personal information.  If you would like more information about LIQUID AVATAR’s use of these service providers, please contact us at support@liquidavatar.com

14. Retention

Due to the nature of LIQUID AVATAR’s business personal data will be kept for as long as LIQUID AVATAR provides services to the user.  LIQUID AVATAR provides “Always On” ID Verification, KYC and AML screening and verification.  As such, we require user information such as full names, residential address, government identification and proof of current address to be provided.  LIQUID AVATAR must ensure that KYC and AML screening is “Always ON” in order to be kept up to date and therefore must retain personal information for as long as LIQUID AVATAR continues to provide services to the user. 

Customer Service interactions result in the capture of certain information such as names and email addresses.  Upon completion of a customer service ticket, such information will be kept on file by the Companies for 30 days and then deleted, with the exception of tickets for Liquidshopz.  All customer personally identifying information from Liquidshopz tickets will be deleted 30 days after the ticket has been completely resolved.  Other, non-identifying information will be retained by the Companies to allow for the on-going evaluation of Liquidshopz merchant issues and responses.

15. Updates or Changes to LIQUID AVATAR Policies

LIQUID AVATAR may modify or update this Privacy Policy from time to time, so please review it periodically. If the Companies make any material changes in the way it collects, uses, and/or shares the personal information that you have provided, the Companies will notify you by posting notice of the changes in a clear manner. Your continued use of LIQUID AVATAR’s Services after any modification to this Privacy Policy will constitute your acceptance of such modification.

16. Your Choices and Rights

Subject to local law, you may have certain rights regarding information that LIQUID AVATAR has collected and that is related to you. Please contact LIQUID AVATAR to update or correct your information if it changes or if you believe that any information that we have collected about you is inaccurate or out of date. You can also ask to see what personal information LIQUID AVATAR retains about you, and to erase your personal information. If you would like to exercise the rights you may have, please contact us at support@liquidavatar.com.

Although LIQUID AVATAR strives to provide individuals with access to their personal information, there may be instances where LIQUID AVATAR may not provide access, including but not limited to: where the information would put another individual’s privacy at risk, where the access would reveal confidential commercial information, or the requested information contains legal privilege. If LIQUID AVATAR determines that access should be limited in any specific instance, the Companies will provide an explanation of why that assessment has been made and a contact point for any further concerns.

17. Children’s Privacy

LIQUID AVATAR does not knowingly collect or solicit any information from anyone under the age of 13, under the age of online consent in the child’s jurisdiction of residence, or from a minor in a jurisdiction where parental / guardian consent for the collection of information is required until the age of majority in that jurisdiction, or knowingly allow such persons to register for the Service. The Service and its content are not directed at children under the age of 13. In the event that LIQUID AVATAR learns that the Companies have collected personal information from a child under the age of 13 or under the age of online consent in their jurisdiction of residence without parental consent, or from a minor in a jurisdiction where parental / guardian consent for the collection of information is required until the age of majority in that jurisdiction, LIQUID AVATAR will delete that information as quickly as possible. If you believe that LIQUID AVATAR might have any information from or about a child that requires parental or guardian consent, please contact LIQUID AVATAR.

In some cases our services may be utilised by governmental bodies for the purposes of facilitating student identification for government approved education.  In all such cases, parental / guardian consent will be required for the collection of personal information for participating minors.

16.California Consumer Protection Act of 2018

This section of the privacy policy and notice for California residents applies solely to visitors, users, and individuals, who reside in the State of California (“consumers” or “you”).

We have adopted this notice to comply with the California Consumer Privacy Act of 2018 (CCPA). 

The terms “business,” “business purpose”, “personal information”, “processing”, and “service provider” have the meanings giving to them in the CCPA.

Liquid Avatar Technologies Inc. and all affiliates and subsidiaries, (collectively “LIQUID AVATAR” “we” or “us”) may collect and use consumer personal information for its commercial and business purposes and related operational purposes. With respect to these activities, LIQUID AVATAR may have direct responsibilities as a business subject to the CCPA. For example, for certain activities related to direct interaction with consumers who have a direct relationship with LIQUID AVATAR, interacting with prospective/current clients, marketing, websites/web applications use, engaging vendors, and interacting with visitors/users of our websites. In these cases, this privacy policy is applicable.

LIQUID AVATAR also collects information in its capacity as a service provider to our clients, providing Proof of Humanity credentials, Meta Park Pass credentials, ID verifications, KYC/AML (“Know Your Customer” and “Anti-Money Laundering”) services and other related financial services. In that case, LIQUID AVATAR receives personal information directly from individual customers and in some cases, from our clients where we have no direct relationship with the individuals whose personal information we process, and information is provided to us solely for the business purpose of providing those services.

Categories of Personal Information We Collect

The specific personal information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on the level of ID verification processed, however, LIQUID AVATAR never sells or discloses your personal information to third parties.

We have collected and used for business purposes, personal information relating to California residents covered by this policy which may include:

Sources of Personal Information We Collect

• Information directly from you, the consumer that you choose to provide, when you interact with us, for example, when you register for ID verification.
• Information we automatically collect when you interact with our websites, content or emails such as your IP address and the pages you visited, and when you use our services, we may collect information on how you use those services. Please see our Section 7 of this Policy for information our use of Cookies additional information.
• Information provided by our clients in order for us to provide specific services as a service provider, or information from third parties, acquired at the direction of our clients in order to provide the services.
• Information from other sources, including service providers or publicly available sources.
• Information to improve our systems, including screens visited, interaction patterns (screen actions, gestures: taps scrolls), and device details (type, version, model, operating system).

Business Purposes

We collect personal information to offer and administer our services and products. These include:

• To provide the products or perform services for our clients pursuant to a written agreement, including contacting you in the course of our ordinary commercial relationship, verifying client information, or similar activities as needed to provide services for or on behalf of our clients.
• For marketing purposes. For example, where you have previously opted in, we may use your information to further discuss your interest in our services and to send you information regarding Liquidshopz and other such services and opportunities. You may opt-out of receiving email and SMS marketing communications and updates at any time. 
• To improve our communications with you. Emails sent to you by LIQUID AVATAR may include standard tracking, including open and click activities. LIQUID AVATAR may collect information about your activity as you interact with our email messages and related content in order to verify or maintain the quality of our communications, or improve, upgrade, or enhance the services we provide.
• For operating and improving LIQUID AVATAR’s websites/web applications and your customer experience, including debugging to identify and repair errors that impair existing intended functionality or to verify or maintain the quality of our websites, and to improve, upgrade or enhance the websites services. For example, we may collect and analyze data on your use of our websites and process it for the purpose of improving online user experience. Please see our Terms of Use Policy for additional information.
• For security purposes, including detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.
• For other business purposes, which will be disclosed at the time we collect personal information.

Disclosure/Sharing of Personal Data

In the preceding 12 months, we have not sold any personal information.

We share personal information for business purposes with the following categories of third parties:

• Our affiliates, as needed to operate our business and provide services.
• Service providers, such as vendors, consultants and other service providers who perform certain services on behalf of LIQUID AVATAR, in which case we enter into a contract that describes the purpose of processing and requires the recipient to not use it for any purpose except performing the contract.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

Your Rights

Subject to the CCPA and other applicable laws, you have the following rights concerning your data processed by LIQUID AVATAR:

• Access: You have the right to request to access the personal information that LIQUID AVATAR holds about you, including categories of information collected, categories of sources from which the information is collected, our business purpose for collecting information, and categories of third parties with whom we share your information.
• Deletion: You can request that LIQUID AVATAR erase your personal data. Please see Section 11 above.
• Non-discrimination: LIQUID AVATAR will not discriminate against a consumer because the consumer exercised any of the consumer’s rights under the CCPA.

17. Virginia Privacy Rights

The Virginia Consumer Data Protection Act (“CDPA”) provides Virginia consumers with specific rights regarding their Personal Information.  This section describes your rights under the CDPA and explains how you may exercise these rights.

The categories of Personal Information we process, our purposes for processing your Personal Information, the categories of Personal Information that we share with third parties, and the categories of third parties with whom we share it are detailed above in our Privacy Policy.

Certain rights that you may have concerning your Personal Information are set forth in our Privacy Policy.  The CDPA provides you with the following additional rights:

• Right to know. You have the right to know whether we process your Personal Information.
• Right to portability. You have the right to access and obtain a copy of your Personal Information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business without hinderance, where the processing is carried out by automated means.  You may request such Personal Information up to twice annually, subject to certain exceptions.
• Right to delete. You have the right to delete Personal Information that you have provided or that we have obtained about you.  We may deny such a request if the requested deletion falls under an exception to this right set forth in the CDPA.  Additionally, if you request deletion of your Personal Information and we have obtained such information from a third-party source, we may retain such data by keeping a record of the deletion request and the minimum data necessary to ensure that your Personal Information remains deleted from our records and that such retained data is not used for any other purpose, or we may opt you out of the processing of such Personal Information for any purpose except for those allowed under the CDPA.
• Right to opt out of selling or sharing. You have the right to opt out of the processing of the personal information for purposes of: (i) targeted advertising; (ii) the sale of Personal Information; or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.  As of the latest date of the Privacy Policy:
• We DO NOT process personal information for the purposes of targeted advertising unless we first obtain your explicit permission to do so;
• We DO NOT sell your Personal Information in exchange for monetary consideration;
• We DO NOT engage in profiling decisions based on your personal information that produce legal or similarly significant effects concerning you.

If you wish to opt out of the processing of your Personal Information, for the purposes of targeted advertising, please contact us here.

• Right to correct. You have the right to correct inaccuracies in the Personal Information we collect from you, taking into the account the nature of the Personal Information and the purposes for which we process it.
• Right to non-discrimination. You have the right not to receive discriminatory treatment by us for the exercise of your Virginia privacy rights.  Unless permitted by the BDPA we will not:
• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Providing you a different level or quality of goods or services;
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

To exercise any of your Virginia privacy rights, or if you have any questions about your privacy rights, you may contact us.

After submitting a request, we will take steps to verify your identity in order for us to properly respond and/or confirm that it is not a fraudulent request.  You represent and affirm that all information you provide in response to such a request to verify your identity is true and accurate.  If we are unable to verify using reasonably commercial efforts that the consumer submitting the request is the same individual about whom we have collected Personal information, then we are not required to comply with the request; we may contact you for more information reasonably necessary to authenticate the request, but ultimately we may not be able to meet your request.

Only you or an agent legally authorized to act on your behalf, may make a verifiable request related to your Personal Information.  If you are making a request as the authorized agent to a Virginia consumer, we will ask you also submit reliable proof that you have been authorized in writing by the consumer to act on such consumer’s behalf.

We will make every effort to respond to your request within 45 days from when you contacted us.  If you have a complex request, the CDPA allows us up to 90 days to respond.

If we decline to take action regarding a request that you have submitted, we will inform you of our reason for declining to take action and provide such instructions for how to appeal the decision.  In the event that we don not respond to a request that you make pursuant to one of the privacy rights set forth in this section, you have the right to appeal our refusal and take action within a reasonable period of time after you receive your decision.  Within 60 days of our receipt of an appeal, we will inform you in writing of any actin taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.  If the appeal is denied, we will also provide you with an online mechanism, if available, or other method through which you may contact the Attorney General to submit a complaint.

18. EEA, UK or Switzerland Privacy Rights

In the course of using the Liquid Avatar services, we may process the following information:

• ID documentation, which may include your government issued identification, a live “selfie” picture f yourself, and a form of utility bill or bank statement. The required information will depend on the level of service you request from Liquid Avatar.  We will process this information to provide you with the Liquid Avatar services.  The legal basis for this processing is Article sec. 1 sent. 1. Lit. b (“performance of a contract”) and lit. f (“legitimate interest”) GDPR.  It is in our legitimate interest to guarantee the Liquid Avatar services stability and security.
• Login information, which may include your IP address, device type, date and time of your visit, information on your browser version, information on your operating system, including language settings and MAC addresses. We will process this information to provide you with Liquid Avatar services.  The legal basis for this processing is Article sec. 1 sent. 1. Lit. b (“performance of a contract”) and lit. f (“legitimate interest”) GDPR.
• Any and all data required for providing requested credentials which may include location information, user-generated content, contact details and other Personal Information that are used for participating in the Services we are offering. We process this information to provide our Services to you.  The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR (“Performance of a contract”).
• Email addresses or phone numbers you provided us with for added verification and/or to enable certain features. The basis for processing this personal data is Article 6 sec. 1 sent. 1 lit. b (“performance of a contract”) and f (“legitimate interest”) GDPR.  Liquid Avatar has a legitimate interest in providing safe and secure services, especially to protect children.
• Billing and payment information, when you make a purchase, which may include your name, phone number, email address, billing address, credit card or other payment information and billing information. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”).  Payment information may instead be collected directly by the payment processor and not Liquid Avatar.  In such cases, the privacy policy of the payment processor would apply.  We may also retain transaction details and purchase and payment history.  The legal basis for processing this personal data is our legal obligation in being able to resolve subsequent billing disputes and inquiries, Article 6 sec. 1 sent. 1 lit. c GDPR (“legal obligation”).
• Information relating to contacting our customer services. e.g. When you report a problem, submit questions, concerns or comments. We may process your email address, your name and information relating to your inquiry or concern in order to respond to your communications, fulfill your requests, or provide other customer support.  This processing activity is based on your consent according to Article 6 sec. 1 sent. 1 lit. a GDPR and/or Article 6 sec. 1 sent. 1 lit be GDPR (“performance of a contract”), depending on the initial purpose for contacting our customer support.
• Information processed to enable advertising. To market our services via social media and other website advertisements in order to bring new users to our Liquid Avatar services and to maintain and increase our user base, we may process Personal Information such as IP addresses, information on users’ browser or operating system, including language settings, location information and usernames or user IDs.  The legal basis for the processing of this data is Liquid Avatar’s legitimate interest in maintaining our user base, bringing users to our services and informing (potential) users about interesting events, Article 6 sec 1 sent. 1 lit f GDPR (“legitimate interest”).
• Information relating to the use of location-based service. In order to provide Services such as tagging, check-in and content delivery, or other services that require knowing where you are, we may process your location information.  This processing is based on Article 6 sec. 1 set. 1 lit b GDPR (“performance of a contract”) and/or Article 6 sec. 1 sent. 1 lit. f GDPR (“legitimate interest”) and represents our legitimate interest to improve our website and services experience and to optimize our services.  Please note that you can always stop the collection of location-based information by updating your device settings, stopping your use of Services or uninstalling our applications.
• Information relating to your participation in contests, competitions, sweepstakes, giveaways, price draws or other promotions that we may run on our Services or sponsor from time to time. We may process certain contact information (such as your name, user ID, email address, and/or phone number) for prize fulfillment purposes, as well as other information or content needed for the specific promotion.  The legal basis for the processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”).
• We will use certain cookies only if you have previously consented to such use.  When you visit our website a cookie banner will appear asking your for your consent.  You can manage your choices by clicking on “manage cookie preferences” in the cookie banner.  We will save your choices in the form of a cookie.  This cookie has a limited effective period of one year.  The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. a GDPR (“consent”).  In addition, you can also manage cookies using your browser settings.

If you live in the EEA, the UK or Switzerland, you may be entitled to exercise some or all of the following rights:

• Require (i) we provide you with information on whether your Personal Information is retained, and (ii) provide access to our duplicates or your Personal Information retained, including the purposes of the processing, the categories of Personal Information concerned, and the data recipients as well as potential retention periods;
• Request rectification, removal or restriction of your Personal Information e.g. because (i) it is incomplete or inaccurate, (ii) it is no longer needed for the purposes for which it was collected, or (iii) the consent on which the processing was based has been withdrawn;
• Refuse to provide and, without impact to data processing activities that have taken place before such withdrawal, withdraw your consent to processing of your Personal Information at any time;
• Object, on grounds relating to your particular situation, to processing of your Personal Information, in case such processing is either based on our or a third party’s legitimate interests or on a performance of a task carried out in the public interest. In this case, please provide us with information about your particular situation.  After the assessment of the facts presented by you we will either stop processing your Personal Information or present you our compelling legitimate grounds for an ongoing processing;
• Object to the use of your Personal Information for direct marketing at any time;
• Take legal action in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data protection regulators; and/or
• Require (i) to receive the Personal Information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and (ii) to transmit the data to another controller without hinderance from our side. Where technically feasible, you shall have the right to have the Personal Information transmitted directly from us to another controller.

19. Brazil Privacy Rights

We may process the following personal data:

• ID documentation, which may include your government issued identification, a live “selfie” picture f yourself, and a form of utility bill or bank statement. The required information will depend on the level of service you request from Liquid Avatar.  We will process this information to provide you with the Liquid Avatar services and to guarantee the Liquid Avatar services stability and security.
• Login information, which may include your IP address, device type, date and time of your visit, information on your browser version, information on your operating system, including language settings and MAC addresses. We will process this information to provide you with Liquid Avatar services and to guarantee the Liquid Avatar services stability and security.
• Any and all data required for providing requested credentials which may include location information, user-generated content, contact details and other Personal Information that are used for participating in the Services we are offering. We process this information to provide our Services to you. 
• Email addresses or phone numbers you provided us with for added verification and/or to enable certain features. We use this data to provide safe and secure services, especially to protect children.
• Billing and payment information, when you make a purchase, which may include your name, phone number, email address, billing address, credit card or other payment information and billing information. Payment information may instead be collected directly by the payment processor and not Liquid Avatar.  In such cases, the privacy policy of the payment processor would apply.  We may also retain transaction details and purchase and payment history.
• Information relating to contacting our customer services. e.g. When you report a problem, submit questions, concerns or comments. We may process your email address, your name and information relating to your inquiry or concern in order to respond to your communications, fulfill your requests, or provide other customer support.
• Information processed to enable advertising. To market our services via social media and other website advertisements in order to bring new users to our Liquid Avatar services and to maintain and increase our user base, we may process Personal Information such as IP addresses, information on users’ browser or operating system, including language settings, location information and usernames or user IDs.
• Information relating to the use of location-based service. In order to provide Services such as tagging, check-in and content delivery, or other services that require knowing where you are, we may process your location information.  This information is used to improve our website and services experience and to optimize our services.  Please note that you can always stop the collection of location-based information by updating your device settings, stopping your use of Services or uninstalling our applications.
• Information relating to your participation in contests, competitions, sweepstakes, giveaways, price draws or other promotions that we may run on our Services or sponsor from time to time. We may process certain contact information (such as your name, user ID, email address, and/or phone number) for prize fulfillment purposes, as well as other information or content needed for the specific promotion. 
• We will use certain cookies only if you have previously consented to such use.  When you visit our website a cookie banner will appear asking your for your consent.  You can manage your choices by clicking on “manage cookie preferences” in the cookie banner.  We will save your choices in the form of a cookie.  This cookie has a limited effective period of one year. 

20. Updates to Our Privacy Policy

This policy may be updated periodically to reflect changes in our personal information practices or relevant laws.  We will indicate at the bottom of this policy when this policy was last updated.  Please review this policy every time you access or use the Services to make sure that you have reviewed the most recent version.

21. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at support@liquidavatar.com

22. EU and UK Representative

European Union

According to the GDPR article 27 controllers or processors not established in the European Union providing goods or services to EU citizens must appoint a representative who is established in the EU.

The representative should be an additional or alternative point of contact for all data protection queries from the EU.

• The representative will be an alternative or additional conduit for all data subject enquiries and requests including the exercising of data subjects; rights to information, access, rectification, restriction, portability and notification of processing of personal data by Liquid Avatar as detailed in this privacy policy.

Liquid Avatar have formally appointed Storage and Fitch, GMbbH as their EU representative and will make themselves available to the relevant EU Supervisory Authority if required to do so.

Supervisory authorities and data subjects may contact Storage and Fitech by emailing:

info@gdpr.storageandfitech.de

Or by writing to them at this following address:

Storage & Fitch GmbH

Rowentastrasse 7,

63071 Offenbach,

GER

Phone: +069-85 700 760

United Kingdom

According to the UK GDPR Article 27 controllers or processors not established in the United Kingdom providing goods or services to UK citizens must appoint a representative who is established in the UK.

• The representative should be an additional or alternative point of contact for all data protection queries from the UK
• The representative will be an alternative or additional conduit for all data subject enquiries and requests including the exercising of data subjects rights to information, access, rectification, restriction, portability and notification of processing of personal data by Liquid Avatar detailed in this privacy policy.

Liquid Avatar have formally appointed GDPR Auditing Limited as their UK representative and will make themselves available to the relevant ICO (UK Supervisory Authority) if required to do so.

The ICO and data subjects may contact GDPR Auditing by emailing:

Philip.mather@gdprauditing.com

Or

Vakis.paraskeva@gdprauditing.com

Or by writing to them at this following address:

GDPR Auditing Limited

47 The Lanes, Over

Cambridge

United Kingdom, CB24 5NQ

Or by telephone: +44 (0) 203 488 3050

This Privacy Policy is effective June 1, 2023 and may be changed by LIQUID AVATAR at any time. You are advised to check this policy regularly for any changes.