LedgerLiberty Solutions Inc. (“LedgerLiberty”) is committed to protecting your personal data. This privacy notice (the " Privacy Notice") describes how LedgerLiberty collects, uses, shares, and protects information collected about you on its Websites.
Any personal data you provide or we collect from the use of the LedgerLiberty website will only be used in accordance with this Privacy Notice. This Notice does not apply to personal data of employees or contractors of LedgerLiberty.
This Privacy Notice covers the following:
• What is personal data?
• What are the purposes for the collection, use and disclosure of personal information?
• With whom do we share your data?
• How does LedgerLiberty obtain your consent?
• How long does LedgerLiberty retain your data?
• Data Subject Rights
• Use of technology on the Site
• Your Choices Regarding Relevant Advertisements
• How does LedgerLiberty protect your personal data?
• Contacting LedgerLiberty about your privacy
What is personal data?
Personal data means data about an identifiable or identified natural person, not including business contact information, i.e. data that would allow an employee to be contacted at their place of business. For example, personal data includes such things as your home address and telephone number, your date of birth, your personal email address, and your credit card or other financial information.
What are the purposes for the collection, use and disclosure of your personal data?
LedgerLiberty processes personal data only on legitimate grounds:
• Performance of a contract
• Legal obligation
• Legitimate interests of LedgerLiberty
We do not collect personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and the processing of genetic data, biometric data in order to uniquely identify a person or data concerning health or sex life and sexual orientation. We ask that you not communicate or provide these elements of data to us. We will not use your personal data for decisions based solely on automated processing if the decision produces legal effects concerning you or significantly affects you, unless you gave your explicit consent for this processing.
If you have given LedgerLiberty consent, you may, at any time, unsubscribe or withdraw your consent by contacting LedgerLiberty as set out below, subject to our retention policies and our legal obligations. In some cases, withdrawal of your consent may result in LedgerLiberty being unable to provide you with a particular service through the Site. If so, LedgerLiberty will advise you of the consequences of your withdrawal of consent at the time.
LedgerLiberty collects, uses and discloses your personal data only for identified purposes with your knowledge and consent. LedgerLiberty identifies these purposes to you at the time it collect this information. Some of the purposes for which LedgerLiberty may collect, use and disclose your personal data on this Site are:
To respond to inquiries and requests for one-time or ongoing communications from LedgerLiberty;
• To respond to and process applications for employment with LedgerLiberty; and
• To conduct promotions with you if you have indicated an interest in receiving such promotions.
If you choose not to provide LedgerLiberty with your personal data, the Site will not collect any personal data about you.
LedgerLiberty may disclose your personal data without your permission to the extent that it is required or permitted to do so by European Union or national law, for the following purposes:
• To comply with financial regulations regarding communications with potential and actual investors;
• In connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend LedgerLiberty’s legal rights.
Performance of Contract
LedgerLiberty collects, uses and discloses your personal data in the event you have sought employment, contracting opportunities, or educational opportunities, or solicited business with LedgerLiberty, for the following purposes:
• To comply with commitments made to local authorities regarding hiring, LedgerLiberty may provide information relating to inquiries and hiring from local areas in which LedgerLiberty operates, to evidence compliance with commitments made by LedgerLiberty;
• To comply with commitments made with local authorities regarding local sourcing, engagement with local organizations and groups, or provide educational opportunities (either individually or to groups).
Legitimate interests of LedgerLiberty
LedgerLiberty collects, uses and discloses your personal data to support its legitimate interests in the following categories:
• To monitor and enhance the security of our website and other systems to which it may connect;
• To deliver more a tailored user experience and reducing the amount of manual data entry;
With whom do we share your personal information?
LedgerLiberty may share your personal data with third parties to assist LedgerLiberty to administer activities on the Site, such as website maintenance, to our auditors or other professional advisors, fulfillment of services by third party vendors or otherwise for service promotions. LedgerLiberty may also use service providers to assist in aggregating personal data. If you have provided LedgerLiberty with your personal data, that personal data will not be sold by LedgerLiberty.
How does LedgerLiberty obtain your consent?
LedgerLiberty obtains consent to collect, use and disclose your personal data for the reasonable and necessary purposes set out above. When you provide LedgerLiberty with your information, such as for signing up to receive emails about business developments, you are consenting to the collection, use and disclosure of your personal data for these purposes, in accordance with the principles outlined in this Notice.
How long does LedgerLiberty retain your personal data?
LedgerLiberty will not store your personal data longer than necessary for the purpose for which we have processed your personal data. How long we retain your personal data depends on the type of data and the purpose for which we process your personal data. LedgerLiberty includes regulated entities, which are subject to a variety of records retention requirements, and so may be unable to remove your personal data because of legal obligations. LedgerLiberty will inform you if you request deletion of your personal data if we are unable to comply.
Data Subject Rights
You may request details of personal data which we hold about you. If you would like a copy of the personal data held on you please write to the contact address below. If you believe that any personal data we are holding on you is incorrect or incomplete, please contact us as soon as possible, at the address below. We will promptly correct any personal data found to be incorrect.
You may always choose to object to the collection or use of your personal data whenever personal data is processed for the legitimate interests of LedgerLiberty.
Use of Technology on the Site
The Site uses Cookie technology to make your use of the Site more convenient. A cookie is a text file which enables the Site to store information about your activities on the Site, or the length of your stay. Any personal information that is collected by the cookies will be used only on an aggregate basis, which means that LedgerLiberty takes the identifiers off the information, and uses it for statistical purposes to assist LedgerLiberty in enhancing your online experience, or to evaluate the success of promotions that LedgerLiberty may carry on through the Site. The Site does not collect your personal or financial data from your computer, nor does it place persistent cookies on your computer. The Site will not put cookies on your hard drive. Most web browsers are set to accept cookies by default, however, you should have an option to disable cookies associated with the Site. If you choose to do so, this may affect the functionality of the Site and your ability to access certain features of the Site.
Your Choices Regarding Relevant Advertisements
How does LedgerLiberty protect your personal data?
LedgerLiberty is committed to ensuring that your personal data is secure. In order to prevent unauthorized access or disclosure, we have put in place appropriate technical and organizational measures to safeguard and secure the personal data we process. LedgerLiberty web sites endeavour to use appropriate reasonable security arrangements to prevent any unauthorized access, collection, use, disclosure, copying, modification or disposal of your personal data in accordance with applicable law. LedgerLiberty tries to exercise care in the secure transmission of your personal data, however, no transmission of personal data over the Internet is completely secure. LedgerLiberty cannot guarantee that personal data disclosed through the Internet cannot be intercepted by third parties. However, LedgerLiberty has taken the steps that are reasonably available to LedgerLiberty to protect any personal data that you have provided to LedgerLiberty, including, in its disposal or destruction in due course.
Please remember that you control what personal information you provide while using LedgerLiberty web sites.
If, despite all our efforts, a data breach does occur, LedgerLiberty shall do everything in its power to limit the damage. In case of a data breach which is likely to result in a high risk, and depending on the circumstances, reasonable actions to inform you about remedial actions to prevent further damage, it is our responsibility to inform the relevant supervisory authority or authorities without undue delay.
Contacting us about your privacy
From time to time we may change this Privacy Notice when it is appropriate to do so. We recommend that you review this Notice from time to time so that you are aware of any changes.
Revision Date: October 16, 2018