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🔏 Privacy policy

1. Definitions

1 DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and how any personal data are or are to be processed. For this Privacy Policy, we are a Data Controller of your data.
2 DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers to process your data more effectively.
3 DATA SUBJECT is any living individual who is the subject of Personal Data.
4 THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

2. Personal data

  1. When we refer to personal data in this Privacy policy, we mean any information relating to an identified or identifiable natural person, the Data Subject.
  2. The natural person is not just an abstract “person”. It is a person who can be identified, directly or indirectly, by reference to an identification number or one or more factors specific to their physical, physiological, mental, economic, cultural or social identity and personal history.
  3. A natural person in this context is an identifiable person; it is a similar concept to the individual as used to determine “individual liberty” in Liberland’s Constitution.
  4. You may be entitled to ask Liberland for a copy of your personal data, to correct it, erase or restrict its processing, or to ask us to transfer some of the data to other organisations.
  5. You may also have the right to object to some processing activities, and where we have asked for your consent to process your data, you have the right to withdraw this consent.
  6. Our commercial messages (such as our newsletters) contain unsubscribe links or similar ways to opt-out from these messages. These rights may be limited in some situations – for example, where we can demonstrate that there is a legal requirement to process your data. If you wish to exercise your rights, you can contact us in writing via the contact details in this Privacy policy

3. Policy application

  1. This Privacy policy applies to Liberland Services, meaning services and products offered by Liberland, Liberland Limited, the Liberland marketplace, the Liberland App, and any affiliated persons and other entities, hereafter the “Provider”.
  2. The Provider reserves the right to enact special policies on particular services, and where this happens, the specific policy supersedes this one.
  3. This Privacy Policy does not apply to any other services offered by other persons or entities, including products, vendors, or websites that may include Liberland or Liberland Limited.

4. We need personal data to deliver our services

  1. To deliver Liberland Services to you, the Provider collects, stores, uses and processes your personal data as required by the conditions of that particular service. This Privacy policy or other subsidiary privacy policies where these exist to describe how the Provider collects, stores, uses and processes your personal data.
  2. Before registering to, purchasing, or entering an agreement about or using Liberland Services, please read the respective contract, agreement or description of services carefully and our Terms and conditions, henceforth "Service agreement". These describe your rights and obligations as a party purchasing or otherwise obtaining those services.
  3. Please be mindful that partaking in most Liberland Services requires one to be an E-resident of Liberland, and so the general Terms and Conditions for Liberland.org apply as well. They apply in a subsidiary fashion (where more specific policies are silent), as described in those Terms and conditions.
  4. For other services, such as the Liberland App, the Terms and Conditions applicable to that service apply, likewise in a subsidiary fashion. Please consider these Terms and conditions a part of the Service agreement unless specifically told otherwise.
  5. After entering into the respective agreement for a Liberland service or services, you can always choose not to provide your personal data to the Provider. You must inform the Provider of this, or the Provider can't put your choice can't be put into effect.
  6. Providing the different functionalities and maintaining the expected level of service requires the Provider to have access to your personal data.
  7. Please be mindful that should you choose not to provide your personal data, the Provider can't guarantee to perform the Liberland services to you as stated in the respective Service agreement.
  8. Please be mindful that the Provider is at liberty to interpret such a refusal to provide personal data as the same as a request for the regular termination of the Liberland service. This is mainly where the refusal makes it very difficult or impossible to provide the expected level of service and provide the Liberland service regularly.

5. We process the following kinds of data:

  1. Personal data is necessary so that we can provide you with our services, henceforth "Relation data"; these are
    a. Name or names and surname or surnames;
    b. Titles such as education or academic titles (Mgr. or Prof.), nobility titles ("Sir", "Lady");
    c. User names;
    d. Birthdate;
    e. Telephone number;
    f. Address, both in Liberland and otherwise; registration at the place of residence and actual address;
    g. Nationality or nationalities;
    h. Liberland identification number or numbers where applicable;
    i. Copies of national identification documents such as IDs and Passports;
    j. Payment information, including and not limited to bank accounts or wallet addresses for LLD and LLM and other cryptocurrencies where that is necessary; and k. Email address and other contact information such as Linkedin or Telegram.
  2. We may use and store information about your location if you permit us to do so. Henceforth, we use this data "Location data" to provide features to our services and improve and customise our services.
  3. We use cookies and similar tracking technologies to track our services' activity and hold certain information, henceforth "Cookie data".
  4. The information your browser sends whenever you visit our Service or when you access Sevice by or through any device, henceforth "Usage data".
  5. The "content" of those services that contain personal data, henceforth "Content data"; personal data, Location data and Cookie data we process on our and your behalf, but Content data, which you give to us and you use in your own matters, we process solely on your behalf.
  6. While using our Service, we may also collect the following information: sex, age, place of birth, details of documents on education, qualification, professional training, employment agreements, NDA agreements, information on bonuses and compensation, information on marital status, family members, social security (or other taxpayer identification) number, office location and other data.

6. Purpose for data usage

  1. We use your personal data for the following purposes:
    a. to provide and maintain our Service;
    b. to notify you about changes to our Service;
    c. to allow you to participate in interactive features of our Service when you choose to do so;
    d. to provide customer support;
    e. to gather analysis or valuable information so that we can improve our Service;
    f. to monitor the usage of our Service;
    g. to detect, prevent and address technical issues;
    h. to fulfil any other purpose for which you provide it;
    i. to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
    j. to provide you with notices about your account and/or subscription, including expiration and renewal notices, email instructions, etc.;
    k. to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
  2. in any other way we may describe when you provide the information;
  3. for any other purpose with your consent.
  4. In addition to the purposes mentioned above, we use your personal data for compliance with applicable laws and protection of Liberland and the Provider’s legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, regulatory, investigative purposes (including disclosure of such information in connection with legal process or litigation).

7. Retention of data

  1. We will retain your Personal data only for as long as is necessary for the purposes set out in this Privacy policy.
  2. Our standard retention policy is to delete the data 5 years after the data subject’s relationship has ended with the Provider;
  3. In addition, we will retain and use your Personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
  4. Usage Data is generally retained for a shorter period, e.g. for one year after obtaining the data, except when this data is used to strengthen the security or improve the functionality of our Service, unless we are legally obligated to retain this data for longer periods. In that case, the standard five years after the termination of the relationship applies. We will also retain Usage Data for internal analysis purposes.

8. Transfer of data

  1. Your information, including personal data, may be transferred to – and maintained on – computers outside your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
  2. If you are located outside the United States of America and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States of America and process it there.
  3. Your consent to this Privacy Policy and your submission of such information represents your agreement to that transfer.
  4. The Provider will take all the steps reasonably necessary to ensure that your data is treated securely and by this Privacy Policy, and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place, including the security of your data and other personal information.

9. Disclosure of Data

  1. Under certain circumstances, we may be required to disclose your Personal Data if required by law or in response to valid requests by public authorities.
  2. If our subsidiaries or we are involved in a merger, acquisition or asset sale, we may transfer your Personal Data.
  3. In other cases. We may disclose your information also:
    a. to our subsidiaries and affiliates;
    b. to contractors, service providers, and other third parties we use to support our business;
    c. to fulfil the purpose for which you provide it;
    d. for the purpose of including your company's logo on our website;
    e. for any other purpose disclosed by us when you provide the information;
  4. with your consent in any other cases;
  5. if we believe disclosure is necessary or appropriate to protect the company's rights, property, or safety, our customers, or others.

10. Security of Data

  1. The security of your data is important to us but remember that no method of transmission over the Internet or electronic storage is 100% secure.
  2. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

11.1. GDPR

  1. If you are a European Union (EU) and European Economic Area (EEA) resident, you have certain data protection rights covered by GDPR. We aim to take reasonable steps to allow you to correct, amend, delete, or limit your personal data use.
  2. If you wish to be informed of what Personal Data we hold about you and if you want it to be removed from our systems, please email us at [email protected].
  3. You have the following data protection rights:
    a. The right to access, update or delete the information we have on you;
    b. The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
    c. the right to object. You have the right to object to our processing of your Personal Data;
    d. the right of restriction. You have the right to request that we restrict the processing of your personal information;
    e. the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;
    f. the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information;
  4. Please note that we may ask you to verify your identity before responding to such requests. Please note that we may not be able to provide Service without some necessary data.
  5. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. Please contact your local data protection authority in the European Economic Area (EEA) for more information.

11.2. CalOPPA

  1. CalOPPA is the first state law in the United States of America to require commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require a person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website. The policy should state which types of information will be collected and those individuals with whom the data controller will share it.
  2. According to CalOPPA, we agree to the following:
    a. users can visit our site anonymously;
    b. our Privacy Policy link includes the word "Privacy", and you can easily find it on the home page of our website;
    c. we will notify users of any privacy policy changes on our Privacy Policy Page;
    d. we allow users to change their personal information by emailing us at [email protected].
    e. We honour Do Not Track signals and do not track plant cookies or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting your web browser's Preferences or Settings page.
  3. If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data, and not sell (share) it. To exercise your data protection rights, you can make certain requests and ask us:
  4. What personal information do we have about you. If you make this request, we will return to you: a. the categories of personal information we have collected about you;
    b. the categories of sources from which we collect your personal information;
    c. the business or commercial purpose for collecting or selling your personal information;
    d. the categories of third parties with whom we share personal information;
    e. the specific pieces of personal information we have collected about you;
    f. a list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your personal information, we will inform you of that fact;
    g. a list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with;
  5. Please note that you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the personal information we collected about you in the previous 12 months.
  6. To delete your personal information. If you make this request, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate.
  7. To stop selling your personal information. We don't sell or rent your personal information to any third parties for any purpose. We do not sell your personal information for monetary consideration. However, under some circumstances, a transfer of personal information to a third party, or within our family of companies, without monetary consideration may be considered a "sale" under California law. You are the only owner of your Personal Data and can request disclosure or deletion at any time. If you submit a request to stop selling your personal information, we will stop making such transfers. Please note that asking us to delete or stop selling your data may impact your experience with us. You may not be able to participate in certain programs or membership services that require using your personal information to function. But in no circumstances we will discriminate against you for exercising your rights.
  8. Please send your request(s) by email: [email protected] to exercise your California data protection rights described above.
  9. Your data protection rights, described above, are covered by the CCPA, short for the California Consumer Privacy Act. The CCPA took effect on 01/01/2020. To find out more, visit the official California Legislative Information website.

12. Service providers

  1. We may employ third-party companies and individuals to facilitate our service, “Service Providers”, provide service on our behalf, perform Service-related services or assist us in analysing the use of our service.
  2. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

13. CI/CD tools

We may use third-party Service Providers to automate the development process of our Service.

14. Behavioral Remarketing

We may use remarketing services to advertise on third party websites after you visit our Service. Our third-party vendors and we use cookies to inform, optimise and serve ads based on your past visits to our Service.

15. Payments

  1. We may provide paid products and/or services within Liberland services. In that case, we may use third-party services for payment processing (e.g. payment processors).
  2. We will not store or collect your payment card. That information is provided directly to our third-party payment processors, whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
  3. We may offer direct payments in cryptocurrency to a wallet address. The payments are stored on their respective blockchain according to the rules of that blockchain. Please make sure you understand the privacy policy of that blockchain before using it to pay us, as the Provider shall not be liable for the consequences of your payment method. The Provider merely allows you to pay using these methods for your convenience.

16. Links to Other Sites

  1. Our Service may contain links to other sites that we do not operate. You will be directed to that third party’s site if you click a third-party link. We strongly advise you to review the privacy policy of every site you visit.
  2. We have no control over and assume no responsibility for any third-party sites or services' content, privacy policies, or practices.

17. Children’s Privacy

  1. Our Services are not intended for use by children under the age of 18 (“child” or “children”).
  2. We do not knowingly collect personally identifiable information from children under 18. Please contact us if you become aware that a child has provided us with Personal Data. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

18. Changes to This Privacy Policy

  1. We may update our Privacy Policy from time to time and reserve the right to do so at any time with or without disclosing a reason. We will notify you of any changes by posting the new Privacy Policy on this page.
  2. We will notify you via email and/or a prominent notice on our Service before the change becomes effective and update the “effective date” at the top of this Privacy Policy.
  3. We advise you to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when posted on this page.

19. Contact Us

If you have any questions about this Privacy Policy, don't hesitate to contact us by email: [email protected].