1. Who is responsible for your data
Libertum Ltd is the controller of personal data processed through the libertum.io website and the T-Suite platform. Libertum Ltd is a private limited company incorporated in England and Wales on 3 February 2023 under company number 14638562, with its registered office at 15 Crammavill Street, Grays, England, RM16 2AP.
Libertum, S.A. de C.V., Av. La Revolución, Presidente Plaza, level 6, office 12, San Salvador, El Salvador, is the controller of personal data processed to provide its digital asset services (custody, including custodian wallets, exchange and transfer of digital assets, and receipt and transmission of client orders) and to meet its own anti-money-laundering, sanctions and regulatory obligations as a Digital Asset Service Provider registered with the Comisión Nacional de Activos Digitales (CNAD) under registry entry PSAD-0094.
In this policy, “Libertum”, “we” and “us” mean Libertum Ltd and, for the processing described above, Libertum, S.A. de C.V.
Issuers and white-label tenants. Issuers whose offerings you invest in, and organisations that operate a white-label portal, also use your information for their own purposes, for example to keep their register of holders, decide on your eligibility and meet their legal obligations. For that use the issuer or tenant is responsible as an independent controller under its own privacy notice, which you should read. Where a tenant uses its own verification account with our identity-verification provider, your verification on that portal is processed under the tenant’s account.
Our contact for data protection. Our Compliance Officer is the data protection lead for the Libertum group. You can reach them at [email protected] (subject “Privacy request”) or by post at either address above.
2. The information we collect
| Category | Examples | Source |
|---|---|---|
| Identifiers and contact details | Name, email, telephone, postal address, user name, account ID, country of residence, IP address | You; your device |
| Identity verification (KYC/KYB) | Date of birth, nationality, government ID document and number, selfie and liveness video, proof of address; for organisations: registration documents, directors, authorised signatories and beneficial owners | You, through Sumsub |
| Biometric data | Facial geometry derived from your selfie and ID photo, used only for face matching and liveness checks | Sumsub, from your images |
| Screening results | Sanctions, politically-exposed-person and adverse-media results | Sumsub |
| Investor status | Answers about accredited, qualified or professional investor status, supporting documents and the declaration you sign (with time and IP address) | You |
| Financial and transaction data | Orders, amounts, payment method, bank-wire references, card payment status (card numbers are handled by Stripe and not stored by us), token holdings, distributions, redemptions, withdrawals, invoices and subscriptions | You; issuers; payment providers; blockchains |
| Wallet data | Addresses of custodian wallets we provision for you and of external wallets you connect, register or withdraw to; on-chain transaction history | Us; you; public blockchains |
| Security data | Password (stored only as a one-way hash), two-factor settings, single-use codes, login and session records, audit logs | You; your device |
| Communications | Support tickets, disputes, complaints, emails and messages, contact-form submissions and call bookings | You |
| Device and usage data | Browser, operating system, pages used, errors and, on the T-Suite application, session replays captured by our error-monitoring service | Your device |
| Organisation and workspace data | Information issuers, asset managers and fund managers enter about their organisation, team, assets, offerings, funds and documents, including drafts prepared in Structuring | Organisations |
| Prospect data (Distribution Hub) | Contact and professional details of prospective investors entered or imported by an organisation, or found by Libby AI in public sources; for organisations that connect it, read-only access to their Gmail inbox | Organisations; public sources; Google |
| Website analytics and marketing data | Cookie identifiers, pages visited, interactions, approximate location derived from IP address, and (only if you accept marketing cookies and submit a form) a hashed email address used for conversion measurement | Your device; see our Cookie Policy |
Some of this information, such as biometric data and data revealing sanctions or politically-exposed-person status, is special category or otherwise sensitive data. We process it only where the law allows it, as explained in section 3.
3. How we use information and our legal bases
Under the UK GDPR (and the EU GDPR where it applies), we must have a legal basis for each use of your personal data:
| Purpose | Legal basis |
|---|---|
| Opening and running your account; provisioning custodian wallets; processing subscriptions, payments, token delivery, distributions, redemptions, secondary-market trades and withdrawals; keeping holder records for issuers | Performance of our contract with you; for organisations, our legitimate interest in providing the service to them and their users |
| Identity and business verification, sanctions and PEP screening, investor eligibility and investment limits, anti-money-laundering monitoring and reporting, responding to authorities, record-keeping | Compliance with legal obligations; our legitimate interest in preventing financial crime; for biometric data, your explicit consent given in the verification flow and, where applicable, the substantial public interest in preventing fraud and unlawful acts |
| Protecting you and the platform: two-factor authentication, single-use codes, fraud and abuse prevention, freezes where required, security investigations and error monitoring | Our legitimate interest in keeping T-Suite and its users secure; compliance with legal obligations |
| Service communications by email (for example verification codes, order and withdrawal updates, invoices) and answering support requests and complaints | Performance of our contract; compliance with legal obligations (complaints) |
| Sharing your investment activity with the issuer of the offering (section 4) | Performance of your investment relationship; the legitimate interests of the issuer and of Libertum |
| AI-assisted features used by organisations (Libby AI, Structuring, Funds) | Performance of our contract with the organisation; our legitimate interest in providing those features |
| Libby AI research of publicly available professional information (section 6) | Our legitimate interest, and that of organisations using Distribution Hub, in identifying and contacting relevant professional investors |
| Improving T-Suite by analysing errors and usage | Our legitimate interest in maintaining and improving our services |
| Website analytics and advertising measurement | Your consent, given through our cookie banner (see our Cookie Policy) |
| Answering contact forms and call bookings; sending news about our services to business contacts | Our legitimate interest in responding to enquiries and promoting our services; your consent where the law requires it. You can unsubscribe at any time |
| Billing, accounting, tax and audit | Compliance with legal obligations; performance of our contract |
| Establishing, exercising or defending legal claims; corporate transactions | Our legitimate interests |
Where we rely on legitimate interests, we have weighed them against your rights; you can ask us for details and you can object (section 11). Where we rely on consent, you can withdraw it at any time without affecting earlier processing.
5. Service providers and other recipients
We share personal data with the following recipients only as needed for the purposes in this policy. Our service providers process data on our instructions under written contracts.
| Recipient | Purpose |
|---|---|
| Sumsub | Identity and business verification, liveness and face matching, sanctions, PEP and adverse-media screening |
| Microsoft Azure | Hosting of the T-Suite servers, database and uploaded documents |
| Cloudflare | Hosting and delivery of the libertum.io website and T-Suite applications, white-label custom domains and link previews, and our website contact-form system |
| Twilio SendGrid | Sending service and transactional emails |
| Stripe | Card payments, subscription billing and network-fee billing |
| Anthropic | AI models used by Libby AI, Structuring and other AI-assisted features |
| Sentry | Error monitoring and session replay of the T-Suite application |
| Read-only Gmail access for organisations that connect their inbox to Distribution Hub; call-booking calendar; website analytics and advertising (Google Analytics, Google Ads and Google Tag Manager, subject to your cookie choices) | |
| Microsoft (Clarity), Meta, LinkedIn and X | Website analytics and advertising measurement, as described in our Cookie Policy |
| Blockchain infrastructure providers (such as Tatum and Blockfrost, and public network nodes) | Reading from and submitting transactions to public blockchains |
| Bridge | Fiat on- and off-ramp services, only if you choose to use them where available (Bridge acts under its own terms and privacy policy) |
| Issuers, their transfer agents and administrators | Administering your investment in their offering (section 4) |
| White-label tenants | Operating the portal you use and, where you register on their portal, reviewing verification and accreditation |
| Professional advisers and auditors | Legal, accounting and audit services |
| Authorities | Where required by law, regulation or court order, or to protect rights and safety, including the CNAD, financial intelligence units, tax authorities and law enforcement |
| Corporate transactions | A buyer or successor of all or part of our business, subject to this policy |
Public blockchains. Token transfers and balances are recorded on public blockchains (Ethereum, Base, Polygon, Arbitrum, BNB Smart Chain, Cardano and the XRP Ledger). That information is public and permanent and cannot be changed or deleted by us. We do not publish your name on-chain; your on-chain identity record contains a verification claim, not your documents.
6. Distribution Hub and publicly sourced data
This section is for people whose professional details appear in an organisation’s Distribution Hub workspace, for example as a prospective investor.
What we collect and where from. When an organisation uses Libby AI, we search public sources (such as firm websites, regulator registers and filings, and reputable press) for firms and the professionals who work for them. We collect name, role, firm, professional contact details published by the firm, and the source of the information. Libby does not collect personal mobile numbers or private email addresses and does not access LinkedIn or other social networks. Organisations may also enter or import prospect details themselves; they are responsible for that data.
Why. To help organisations identify and contact professional investors who may be interested in their offerings. The legal basis is legitimate interests. Libby results are generated by AI and may be inaccurate; we do not use them to make decisions about you that have legal or similarly significant effects.
Who sees it. The organisations whose searches return your information. We may keep research results in a shared research store so that the same public information does not have to be collected repeatedly.
Your choices. You can object or ask for erasure at any time by emailing [email protected]. We will remove you from all Distribution Hub workspaces and keep a minimal suppression record so that you are not added again by Libby.
Gmail. If an organisation connects its Gmail inbox, we access it with Google’s read-only permission to show relevant correspondence in its workspace. We cannot send email from the account, and the access token is stored encrypted.
7. AI features and automated decisions
When organisations use AI-assisted features (such as Libby AI, Structuring drafting and translation, or AI assistance in Funds), the content they submit and relevant workspace data are sent to our AI provider, Anthropic, to produce the result.
Identity verification uses automated checks by Sumsub (such as document authenticity, face matching and screening). You cannot invest until verification has passed, but final decisions to reject or freeze are taken or reviewed by people, and you can ask for a manual review of any verification decision. We do not otherwise make decisions based solely on automated processing that produce legal or similarly significant effects about you.
8. International transfers
Libertum operates from the United Kingdom and El Salvador and uses service providers in the United States, the European Union and other countries, so your data may be processed outside the country where you live. Where UK or EU law requires it, we transfer personal data only to countries recognised as providing adequate protection or under appropriate safeguards, such as the standard contractual clauses approved by the European Commission with the UK Addendum, or the UK International Data Transfer Agreement. You can ask us for more information about these safeguards.
9. How long we keep information
We keep personal data for as long as your account is open and afterwards for as long as needed to meet legal, regulatory, tax and audit obligations, to resolve disputes and to enforce our agreements. In particular:
- identity verification records, screening results, accreditation records and transaction records (orders, payments, mints, transfers, trades and withdrawals, including blocked withdrawals), as well as freezes and seizures, are kept for at least five years after the end of our relationship with you or the date of the transaction, or longer where applicable anti-money-laundering law in El Salvador or in the issuer’s jurisdiction requires;
- complaint records and correspondence are kept for at least five years from closure of the complaint;
- records of privacy-rights requests are kept for at least 24 months;
- billing and accounting records are kept for the periods required by tax and company law;
- website analytics data is kept for the periods described in our Cookie Policy; and
- contact-form and prospect data is kept while it is relevant to the purpose for which it was collected, or until you object.
When an account is closed, we remove the profile, contact details, custodian wallet records and settings, but keep the records the law requires us to keep. Information held by Sumsub is retained under its terms with us. Information recorded on public blockchains cannot be deleted. Information that is no longer needed is deleted or de-identified.
10. How we protect information
We use technical and organisational measures appropriate to the risk, including:
- passwords stored only as salted one-way hashes;
- two-factor authentication by authenticator app for all accounts, and single-use codes for withdrawals;
- sessions that expire after a period of inactivity (60 minutes by default);
- custodian wallet private keys, two-factor secrets and connected-inbox tokens encrypted with AES-256-GCM;
- identity documents held by Sumsub, and sensitive documents uploaded to T-Suite served only through short-lived signed links;
- access to administration tools limited to authorised staff, with key actions logged; and
- error reports filtered to remove credentials and access tokens before they leave your browser.
No method of transmission or storage is completely secure. If a personal data breach is likely to put your rights at risk, we will notify you and the competent authorities as the law requires. More information is on our Security page.
11. Your rights
Under the UK GDPR, and the EU GDPR where it applies to you, you have the right to: be informed about how we use your data; access a copy of it; have inaccurate data corrected; have data erased; restrict our use of it; receive data you provided to us in a portable format; object to processing based on legitimate interests and, at any time, to direct marketing; withdraw consent where we rely on it; and not be subject to decisions based solely on automated processing that produce legal or similarly significant effects. Some rights are limited, for example where we must keep records to meet anti-money-laundering obligations.
How to exercise them. Email [email protected] from the email address on your account (subject “Privacy request”), or have an authorised representative do so with your written permission. We will verify your identity, normally by confirming control of your account email, and will respond within one month. Where a request is complex or we receive many requests, we may extend this by up to two further months and will tell you why.
Complaints to a regulator. You can complain to the UK Information Commissioner’s Office (ico.org.uk, 0303 123 1113) or, if you live in the European Economic Area, to the data protection authority of your country. We would appreciate the chance to deal with your concern first.
Other countries. If you live elsewhere, including El Salvador or a US state with a consumer privacy law, you may have similar rights under local law, and we will honour them to the extent that law provides. We do not sell personal data or share it for cross-context behavioural advertising on T-Suite, and we will not discriminate against you for exercising your rights.
Marketing and service messages. You can stop marketing emails using the unsubscribe link in them. You cannot opt out of service and security messages while your account is open.
13. Children
Our website and T-Suite are not intended for anyone under 18. We do not knowingly collect personal data from children; if we learn that we have, we will delete it.
14. Changes to this policy
We may update this policy to reflect changes to our services or to the law. We will publish the updated policy on this page with a new “Last updated” date and, where changes are material, tell you by email or in T-Suite before they take effect.
15. Contact us
For any question or request about this policy or your personal data, email [email protected] with the subject line “Privacy request”, or write to Libertum Ltd, 15 Crammavill Street, Grays, England, RM16 2AP, or to Libertum, S.A. de C.V., Av. La Revolución, Presidente Plaza, level 6, office 12, San Salvador, El Salvador.