Privacy Policy

1. Introduction

TRUVERI LTD (trading as LIQUI) ("we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you use our platform at www.liqui.uk.

We are the data controller for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Information We Collect

2.1 Information You Provide

We collect information you provide directly, including:

• Identity Data: Name, title, date of birth
• Contact Data: Email address, telephone number, postal address
• Financial Data: Information about your first charge positions, property details, loan amounts
• Professional Data: Company details, professional qualifications
• Communication Data: Records of correspondence with us

2.2 Information We Collect Automatically

When you use our Platform, we automatically collect:

• Technical Data: IP address, browser type and version, device information, operating system
• Usage Data: Pages visited, time spent on pages, navigation paths, click patterns
• Location Data: General geographic location based on IP address

2.3 Information from Third Parties

We may receive information about you from:

• Public Registers: Companies House, HM Land Registry
• Specialist Lenders: Status updates on introductions
• Analytics Providers: Aggregated usage data

3. How We Use Your Information

3.1 Legal Bases for Processing

We process your personal data on the following legal bases:

Contract: To perform our contract with you, including:

• Processing your invitation and application
• Facilitating introductions to specialist lenders
• Communicating with you about our services

Legitimate Interests: For our legitimate business interests, including:

• Identifying qualifying first charge positions
• Improving our Platform and services
• Marketing our services to you (where appropriate)
• Preventing fraud and ensuring security

Legal Obligation: To comply with legal requirements, including:

• Anti-money laundering checks
• Regulatory reporting
• Responding to legal requests

Consent: Where you have given consent, including:

• Marketing communications (where required)
• Non-essential cookies

3.2 Purposes of Processing

We use your information to:

• Verify your first charge position and eligibility
• Send you personalised invitations
• Facilitate introductions to specialist lenders
• Process your applications
• Communicate with you about our services
• Improve and develop our Platform
• Comply with legal and regulatory obligations
• Detect and prevent fraud
• Send marketing communications (with your consent)

4. Sharing Your Information

4.1 Third Parties We Share With

We may share your personal data with:

• Specialist Lenders: To facilitate introductions and process applications. They will process your data under their own privacy policies.
• Service Providers: Including IT providers, analytics services, and professional advisers who process data on our behalf.
• Legal and Regulatory Bodies: Where required by law or to protect our legal rights.
• Business Transfers: In connection with any merger, acquisition, or sale of assets.

4.2 International Transfers

We primarily store and process data within the UK and EEA. If we transfer data outside this area, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the UK Information Commissioner's Office.

5. Data Retention

We retain your personal data only for as long as necessary for the purposes set out in this policy. Retention periods depend on:

• The nature of the data
• Legal and regulatory requirements
• Whether there is an ongoing relationship with you
• Our legitimate business needs

Generally, we retain:

• Application data: 6 years from the end of our relationship
• Marketing data: Until you unsubscribe or 2 years of inactivity
• Technical logs: 12 months

6. Your Rights

Under data protection law, you have the following rights:

• Right of Access: Request a copy of your personal data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your data (in certain circumstances)
• Right to Restrict Processing: Request limitation of processing
• Right to Data Portability: Receive your data in a portable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Where processing is based on consent

To exercise any of these rights, please contact us using the details below. We will respond within one month. We may need to verify your identity before processing your request.

7. Data Security

We implement appropriate technical and organisational measures to protect your personal data, including:

• Encryption of data in transit and at rest
• Access controls and authentication
• Regular security assessments
• Staff training on data protection

While we take all reasonable precautions, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security.

8. Cookies

We use cookies and similar technologies on our Platform. Please see our Cookie Policy for detailed information about the cookies we use and how to manage them.

9. Marketing

We may send you marketing communications about our services where:

• You have requested information from us
• You have used our services and not opted out
• You have given consent

You can opt out of marketing at any time by clicking the unsubscribe link in our emails or contacting us directly.

10. Children's Privacy

Our Platform is not intended for individuals under 18 years of age. We do not knowingly collect personal data from children. If you believe we have collected data from a child, please contact us immediately.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by posting the new policy on our Platform and updating the "Last updated" date. We encourage you to review this policy periodically.

12. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us:

13. Complaints

If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):