Liv-ex privacy statement

About this Privacy Statement

We are Liv-ex Limited (“Liv-ex”), a company registered in England and Wales under company number 3874907 with registered address at Unit 105/106, Metal Box Factory, 30 Great Guildford St, London, SE1 0HS. We operate a business-to-business exchange and provide online and data services (referred to as our “Service” in this statement).

We take the privacy of your information very seriously. This notice is designed to tell you about our practices, as data controller, regarding the collection, use and disclosure of personal data which may be collected in person from you, obtained via our website or apps, or collected through other means such as by an online form, email, or telephone communication.

This notice applies to personal data:

1. provided by our members, customers or clients (“Members”). Please note that our Member may be a business or organisation who employs or engages you;
2. provided by our prospective members, customers or clients and their staff;
3. provided by you (for instance if you are an end-user who is using the services under your employer’s membership or you are visiting our website);
4. collected directly by us through publicly available information; and
5. relating to third party suppliers of ours,

but this notice does not apply to information we hold in relation to our employees and staff, or in respect to personal data which we hold as “processor” (if any).

This notice is governed by the Data Protection Act 2018 and by the retained UK law version of the EU General Data Protection Regulation as incorporated into UK law by the European Union (Withdrawal) Act 2018 (“GDPR”), and any other applicable data or privacy legislation.

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 and registration information of our users who: 1) have registered with us or whose details have been passed to us on behalf of their employer or organisation for whom they work; 2) submit an enquiry to us; or 3) subscribe to any newsletter or other relevant subscription product. Contact information may include your name, surname, company name, job title/role, email address, username, address, telephone (“Contact Information”).

If you subscribe to a newsletter or other regular information we provide, we will process your Contact Information on the basis that you have consented to this and will only send this information to you for as long as you continue to consent.

Otherwise, we process this information to provide our Service 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 Service or as may be required to perform our contract with you.

• Information which we hold because you are a Member of ours (“Member Information”) and which we process during the course of providing our Service.

We process this information on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our Service to you.

• We may hold aggregated and anonymised data based on your use of the Services for our statistical or other business purposes and may also share such content with our Members in accordance with the section “Sharing your information” below. To the extent such aggregated data is shared with third parties, it will not contain any personal data.
• A record of any correspondence or communication between you and us (“Communication Information”).

We process this information when we monitor our relationship with our Members and provide our Service to you on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our Service.

• Transactional information relating to bids or offers made via our exchange service or relating to services used and accessed by you (“Transactional Information”).

We process this information when we provide our Service (as the case may be) on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our Service.

• Information which we hold because you are (or you are employed by) a third-party supplier of ours relevant to the services we provide to our Members (you may for example be a professional adviser, payment processor or add-in software provider) (“Supplier Information”).

We process this information (including contact and financial information), on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to you.

• 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 analyse web traffic or lets you know when you visit a particular site.

Where applicable and necessary, we process Cookie Information on the basis that you have consented to this in order to improve or communicate with you about our services and/or to customise the website according to your personal interests. Otherwise and for other technical information (such as IP address data), we process this on the basis of our legitimate interest in providing our services to you. For more information, please see our Cookies Policy below.

• Marketing information. We may hold information about you in order to provide information about our Service. This may include names, job titles, email addresses, phone numbers, addresses, and other information (“Marketing Information”).

We process this information in order to improve our services, communicate with you about our services or for market research purposes, 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.

We may collect information from you directly, from the organisation for whom you work (such as your contact information and job title/role) or from another third party. If we 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 notice.

Data Retention

Our current data retention policy is to delete or destroy (to the extent we are able to) personal data in accordance with retention periods which are kept under regular review. Our policy is not to hold data for longer than necessary.

The criteria we use in order to determine applicable retention periods are the following:

• The amount of data we hold;
• The sensitivity of the data we hold;
• The risk of harm from unauthorised disclosure;
• Whether it is necessary for us to hold 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, such as our website hosts and other service technology providers.
• If you are a user of our services, from time to time we may share certain data with our Members for statistical and analytical purposes. For instance, on a broader level, we may aggregate certain data with other users’ data and create analytics reports for such organisations however individuals would not be identifiable through such reports.
• In order to enforce any terms and conditions or agreements for our services that may apply.
• If we are sub-contracting services to or otherwise engaging a third party we may provide information to that third party in order to provide the relevant services.
• We may disclose information to our group companies (as the case may be).
• 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).
• 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 reorganisation.
• To protect our rights, property and safety, or the rights, property and safety of our users or other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

If we do supply your personal data 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.

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;
• locating our data processing storage facilities in secure locations;
• 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 data we hold.

We will ensure that our employees and staff are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees or staff 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.

Your privacy rights

With respect to your personal data, you have:

• The right to be informed – a right to know about our personal data protection and 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 – (also referred to as 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 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 – 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,
• Direct Marketing – the right to request that your personal data will not be used to contact you for direct marketing purposes.

All Subject Access Requests and other requests or notifications in respect of your above rights must be sent to us in writing via our Contact Details below.

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 unauthorised 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.

Transferring your information outside the UK or EEA

We will not transfer your personal data in a systematic way outside of the European Economic Area or UK (together referred to as the “European Area”) but there may be circumstances in which certain personal data is transferred outside of the European Area, in particular:

• From time to time, some of our data processors (including third party payment processors or server providers), may be based outside of the European Area. In that case, we will ensure we have an agreement in place with such processors to provide adequate safeguards and a copy of such safeguards will be available on request.
• If you use our services while you are outside the European Area, your information may be transferred outside the European Area in order to provide you with our services or communicate with you.
• We may communicate with individuals or organisations outside of the European Area in providing our services. Those communications may include personal data (such as contact information).
• From time to time your information may be stored in devices which are used by our staff outside of the European Area (but staff will be subject to our cyber-security policies).

If we transfer your information outside of the European Area, and the third country or international organisation in question has not been deemed by the UK Secretary of State to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice.

Contact us

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal data or how it is handled, you can do so via our contact page or by email to [email protected] or post to Anish Chandaria, Liv-ex Limited, Unit 105/106, Metal Box Factory, 30 Great Guildford Street, London SE1 0HS.

Complaints

If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk/ for further assistance.

 

Liv-ex Cookies Policy

About Cookies

A cookie is a piece of data stored locally on your computer or device and contains information about your activities on the internet.

Like most websites and applications, we use cookies to help provide you with the best experience whilst using our Service.

On our site, we use cookies to track users’ progress through the site, allowing us to make improvements based on usage data. We also use cookies if you log in to one of our online services to enable you to remain logged in to that service. A cookie helps you get the best out of the site and helps us to provide you with a more customised service.

We are required to obtain your consent to use cookies.

Types of Cookies

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 and authentication).

Performance / Analytics Cookies – which are used for analytics (e.g. understanding usage on our website).

Functionality Cookies – which collect information about your device to help you customize our service (e.g. remembering your timezone settings or accessing inline help).

Targeting / Advertising Cookies – these cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and any advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

On your first visit to our site from your browser we will display a banner to notify you that we are using cookies. We will only load the Strictly Necessary Cookies and Functionality Cookies until you have clicked the “Accept All” button on our cookies banner. If you click the “Accept All” button our Performance / Analytics Cookies and Targeting / Advertising Cookies will be loaded.

Below is a list of the cookies currently set by us:

Cookie category and name	Purpose
Strictly Necessary Cookie __cf_bm	Domain: .hubspot.com Desc: This cookie, set by Cloudflare, is used to support Cloudflare Bot Management. Duration: 1 hour
Strictly Necessary Cookie __cf_bm	Domain: .hsforms.com Desc: This cookie, set by Cloudflare, is used to support Cloudflare Bot Management. Duration: 1 hour
Strictly Necessary Cookie wpEmojiSettingsSupports	Domain: liv-ex.com Desc: WordPress sets this cookie when a user interacts with emojis on a WordPress site. It helps determine if the user’s browser can display emojis properly. Duration: session
Analytics Cookie _gcl_au	Domain: liv-ex.com Desc: Google Tag Manager sets the cookie to experiment advertisement efficiency of websites using their services. Duration: 3 months
Analytics Cookie _ga	Domain: liv-ex.com Desc: Google Analytics sets this cookie to calculate visitor, session and campaign data and track site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognise unique visitors. Duration: 1 year 1 month 4 days
Analytics Cookie _gid	Domain: liv-ex.com Desc: Google Analytics sets this cookie to store information on how visitors use a website while also creating an analytics report of the website’s performance. Some of the collected data includes the number of visitors, their source, and the pages they visit anonymously. Duration: 1 day
Analytics Cookie _gat_gtag_UA_*	Domain: liv-ex.com Desc: Google Analytics sets this cookie to store a unique user ID. Duration: 1 minute
Analytics Cookie _ga_*	Domain: liv-ex.com Desc: Google Analytics sets this cookie to store and count page views. Duration: 1 year 1 month 4 days
Functional Cookie li_gc	Domain: .linkedin.com Desc:   Linkedin set this cookie for storing visitor’s consent regarding using cookies for non-essential purposes. Duration: 6 months
Functional Cookie lidc	Domain: .linkedin.com Desc:   LinkedIn sets the lidc cookie to facilitate data center selection. Duration: 1 day

Third party cookies

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.

These third-party cookies are likely to be analytical cookies or performance cookies or targeting cookies:

Google, LinkedIn

Refusing cookies

Once you close your browser, our access to the cookie terminates. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. To change your browse settings you should go to your advanced preferences, using the help feature if required. If you disable cookies on your browser, certain features or parts of our service may not function correctly or will have a degraded experience.

Duration

Except for essential cookies, all cookies will expire after 2 years.