“Personal Information” is defined as any information about an identifiable individual.
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 including ID documentation, and a “selfie” picture of yourself. 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.
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 email@example.com
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 email address. When you use the Services to verify your identity through LIQUID AVATAR, the Companies will collect information such as ID Documents (passport, driver’s license, ID card, etc…), document type, scan of the document, country, “selfie” photo, account ID, legal name, national ID number, gender, date of birth, mailing address, IP address, user name, blockchain address, email, local storage, user display settings, Google authenticators, audit logs, and device camera. When you use the Services to verify your identity, LIQUID AVATAR may collect information such as Social Insurance Number, credit records, telephone number, IP Address and utility bills.
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
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.
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.
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.
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.
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.
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
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
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
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
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.
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
11.Transfer of Data
Storage of your personal information
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.
a. 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;
b. 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 firstname.lastname@example.org 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 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 email@example.com
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
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 firstname.lastname@example.org.
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.
LIQUID AVATAR does not knowingly collect or solicit any information from anyone under the age of 13, 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 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
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
LIQUID AVATAR also collects information in its capacity as a service provider to our clients, providing 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:
Examples May Include
Name, alias, postal address, unique personal identifier, online identifier, internet protocol address (IP Address), email address, account name, driver’s license number (for purposes of Identity verification only a visual representation of the ID is provided), passport number (for purposes of Identity verification only a visual representation of the ID is provided), Date of Birth, or other similar identifiers
Personal Information categories described in California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Name, physical characteristics or description (photo only for identity verification), address, telephone number, passport number, driver’s license or state identification card number, date of birth, bank account number (for identity verification purposes only), credit card number (for identity verification purposes only),
Protected classification characteristics under California or federal law
Age, date of birth citizenship (for identity verification only), gender identity (as it applies to your government issued photo identification only),
Inferences drawn from other personal information.
Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies (as they pertain to Liquidshopz and other third party offers).
Browsing history and information regarding a consumer’s interaction with an internet website, application, or advertisement
Physical location or movements.
Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
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 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).
We collect personal information to offer and administer our services and products. These
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 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.
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
Non-discrimination: LIQUID AVATAR will not discriminate against a consumer because the
consumer exercised any of the consumer’s rights under the CCPA.
18.EU and UK Respresentative 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.
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:
Or by writing to them at this following address: Storage & Fitch GmbH
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
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:
Or by writing to them at this following address: GDPR Auditing Limited
47 The Lanes, Over
United Kingdom, CB24 5NQ
Or by telephone: +44 (0) 203 488 3050