Privacy Policy

1.Who we are and what this policy covers

Liberty Marketplaces LLC is an Arizona limited liability company with its principal office at 4539 N 22nd St Ste R, Phoenix, Arizona 85016. Liberty designs, builds and operates custom software for businesses. For the personal information described in this policy, Liberty is the business responsible for deciding how it is used (in some laws, the “controller”).

This policy applies to libertymarketplaces.com (the “Site”), to emails, calls, meetings and other communications with us, and to our relationships with clients, prospective clients, vendors, contractors and partners. It does not apply to:

• software, applications or websites we build or operate for a client, which are governed by that client's own privacy notice (see Section 2.4); or
• other websites and services, even if we link to them, which have their own privacy policies.

Capitalized terms used but not defined here have the meaning given in our Terms of Use.

2.Information we collect

2.1 Information you give us

• Contact details, such as your name, email address, phone number, company, job title and business address, when you email or call us, meet with us, or exchange business information with us.
• Communications, including the content of your messages, any attachments, and notes of calls and meetings.
• Project and contract information, such as information about your business and project, proposals, agreements, and electronic-signature records (for example, the name, title and email typed when signing, the time, and the IP address and browser used).
• Billing information, such as billing contacts, invoices and payment history. Card and bank details are handled by our payment providers and banks; we do not store full card numbers or bank account numbers on our systems.
• Vendor and contractor information needed to work with and pay you, including tax forms where the law requires them.
• Applications, if you apply to work with us, including your résumé and anything else you choose to share.

Please do not send us sensitive personal information (such as health, financial-account or government ID information) unless we specifically ask for it and it is needed.

2.2 Information collected automatically

• Server log data. When you visit the Site, our hosting provider automatically records technical information such as your IP address, browser type and version, operating system, the referring page, the pages you request, and the date and time. We use it to deliver the Site, keep it secure and fix problems.
• Approximate location. A general location (such as city or region) can be inferred from an IP address. We do not collect precise location.
• Cookies. The public Site does not set cookies or use tracking technologies. See Section 5.

2.3 Information from other sources

• Public sources. Business contact information that businesses and their staff make public, such as company websites, press releases, public business directories and government procurement portals, when we identify organizations that may benefit from our services.
• Referrals and partners, when someone introduces you to us.
• Service providers, such as payment confirmations from payment providers and delivery status from our email provider.

2.4 Information we process for our clients

When a client hires us to build or run software, we may process personal information about that client's employees, customers, vendors and other users, such as names, work email addresses and the records they enter. We process that information only on our client's instructions and under our written agreement with the client, which governs its confidentiality, security, retention and return. The client decides how that information is used and is responsible for its own privacy notice. Software we build and run for a client runs in an environment dedicated to that client, with its own database and file storage. We do not copy a client's data into our own systems, combine it with any other client's data, sell it, use it for anyone else or use it to train artificial-intelligence models, and when a client's subscription ends we return or delete its data as our agreement with the client provides. Email sent to a desk address we run for a client's platform is a communication with Liberty, which we keep confidential and use only to carry out that client's requests. If you use software we operate for a client and have a question or request about your information, please contact that client. If you contact us instead, we will pass your request to the client and help them respond.

3.How we use information

We use personal information to:

• respond to your inquiries and communicate with you;
• scope, build, deliver, host, support and improve the software and services our clients hire us for;
• prepare proposals, enter into agreements (including by electronic signature) and perform them;
• invoice, collect payment and keep financial records;
• operate, maintain, secure and improve the Site and our systems, including detecting, investigating and preventing fraud, abuse, spam and security incidents;
• send business contacts information about our services, which you can opt out of at any time (Section 10.1);
• evaluate job and contractor applications;
• comply with laws, regulations, legal process, and tax and accounting obligations, and establish, exercise or defend legal claims; and
• for any other purpose we describe when we collect the information, or with your consent.

We may use tools that automate parts of our work, including artificial-intelligence services, to help organize, summarize and draft responses to messages and documents. We do not use automated processing to make decisions about you that produce legal or similarly significant effects.

We may create de-identified or aggregated information that can no longer reasonably identify you. We use it only for lawful business purposes and will not attempt to re-identify it, except to confirm that our de-identification works.

4.How we share information

We do not sell personal information, and we do not share it for cross-context behavioral advertising or targeted advertising. We disclose personal information only as follows:

• Service providers that perform services for us, such as website hosting and content delivery, cloud databases and file storage, email sending and receiving, productivity and communication tools, artificial-intelligence services used for the tasks in Section 3, payment processing, and accounting and tax services. They may use the information only to provide their services to us and are bound by confidentiality and security obligations.
• Our clients, where you work for or with a client and the information relates to that client's project.
• Professional advisers, such as accountants, auditors, insurers and banks, under duties of confidentiality.
• Legal and safety: when we believe in good faith that disclosure is necessary to comply with a law, regulation, subpoena, court order or other legal process or valid government request; to enforce our agreements; to protect the rights, property or safety of Liberty, our clients or others; or to detect, prevent or address fraud, security or technical issues.
• Business transfers: in connection with an actual or proposed merger, acquisition, financing, reorganization, bankruptcy, receivership or sale of all or part of our business or assets. Any recipient must honor this policy for the information it receives.
• With your consent or at your direction.

We may also share de-identified or aggregated information that cannot reasonably identify you.

Fonts. When the Site loads, your browser downloads the Inter typeface from Google Fonts, so Google receives your IP address and browser information. Google's own privacy policy governs its use of that information.

5.Cookies and similar technologies

The public Site does not set cookies, use web beacons or pixels, run analytics or advertising tags, or track you across other websites. The only cookie we use is a strictly necessary sign-in cookie for Liberty's private administration area, which members of the public cannot access.

Do Not Track and Global Privacy Control. Because we do not track visitors across websites, we do not respond differently to “Do Not Track” browser signals. We treat a Global Privacy Control (GPC) signal as a valid request to opt out of any sale or sharing of personal information, although we do neither.

6.How long we keep information

We keep personal information only as long as reasonably necessary for the purposes described in this policy, unless the law requires or permits a longer period. As a guide:

• Inquiries and correspondence that do not lead to a business relationship: generally up to three years after our last contact.
• Client, contract and billing records: for the length of the relationship and afterwards for as long as tax, accounting, legal and record-keeping rules require, generally at least seven years.
• Server log data: for a limited period set by our hosting provider.
• Applications: generally up to two years.

We may keep information longer where necessary to resolve disputes, enforce our agreements or comply with a legal hold. When information is no longer needed, we delete or de-identify it; copies held in backups are removed on the backups' normal schedule.

7.How we protect information

We use reasonable administrative, technical and physical safeguards designed to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. These include encryption in transit (HTTPS) on the Site and our systems, encryption at rest provided by our hosting and database providers, access limited to people who need it to do their jobs, individual sign-ins, and periodic review of our security practices.

No method of transmission over the internet or of electronic storage is completely secure, so we cannot guarantee absolute security. If we learn of a security breach that affects your personal information, we will notify you and the appropriate authorities as required by law.

8.Third-party websites and services

The Site may link to websites, products and services that we do not operate. We are not responsible for their content or privacy practices, and this policy does not apply to them. We encourage you to read the privacy policy of every site you visit.

9.Where we process information

Liberty is based in the United States, and we and our service providers store and process information in the United States. If you contact us from outside the United States, your information will be transferred to, stored and processed in the United States, where data-protection laws may differ from those in your country. Where the law requires, we take steps to provide appropriate safeguards for such transfers.

10.Your privacy rights and choices

10.1 Your choices

• Business emails. You can opt out of emails about our services at any time by replying “unsubscribe” or emailing hello@libertymarketplaces.com. We will honor your request promptly. We may still send messages about an existing project, agreement or invoice.
• Cookies. The public Site uses none, so there is nothing to switch off.

10.2 Your rights

Depending on where you live, you may have the right to:

• know and access the personal information we hold about you, including the categories, sources, purposes and recipients;
• correct inaccurate personal information;
• delete personal information we hold about you;
• receive a copy of your personal information in a portable format;
• opt out of the sale or sharing of personal information, targeted advertising and certain profiling (we do none of these);
• limit the use of sensitive personal information (we use it only for the purposes the law permits);
• withdraw consent where we rely on it; and
• appeal our decision about a request.

We extend these rights to everyone, wherever you live, subject to the exceptions the law allows (for example, information we must keep to comply with the law or to complete a transaction).

10.3 How to make a request

Email hello@libertymarketplaces.com with “Privacy request” in the subject line, or write to us at the address in Section 17. To protect your information, we will verify your identity by matching information we already hold, for example by confirming the request from the email address we have on file, and we may ask for more information if needed. You may use an authorized agent; we will ask for your signed permission and may ask you to verify your identity directly with us. We will respond within 45 days, and if we need more time (up to another 45 days, where the law allows) we will tell you why. Requests are free unless they are manifestly unfounded or excessive. If we cannot fully meet a request, we will explain why.

10.4 Appeals

If we decline your request, you may appeal by replying to our decision with “Appeal” in the subject line within 60 days. We will respond within the time the law requires. If we deny your appeal, you may contact your state's attorney general.

10.5 No discrimination

We will not deny you services, charge you a different price or give you a different level of quality because you exercised any of these rights.

11.Children's privacy

The Site and our services are intended for businesses and adults. They are not directed to children, and we do not knowingly collect personal information from anyone under 16. If you believe a child has given us personal information, contact us and we will delete it.

12.Additional information for U.S. state residents

12.1 California

This section supplements this policy for California residents under the California Consumer Privacy Act, as amended (“CCPA”). In the past 12 months we have collected the following categories of personal information, from the sources, for the purposes and disclosed for business purposes to the recipients shown:

• No sale or sharing. We have not sold or shared (for cross-context behavioral advertising) personal information in the past 12 months, and we have no actual knowledge of selling or sharing the personal information of anyone under 16.
• Retention. We keep each category for the periods described in Section 6.
• Shine the Light. We do not disclose personal information to third parties for their own direct-marketing purposes.
• Financial incentives. We do not offer financial incentives in exchange for personal information.
• Your rights. You may exercise the rights described in Section 10, including through an authorized agent.

12.2 Other states

Residents of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia and other states with consumer privacy laws may have the rights described in Section 10, including the right to appeal. We honor them for everyone.

12.3 Nevada

We do not sell covered information as defined under Nevada law. You may still submit an opt-out request to hello@libertymarketplaces.com.

13.Visitors from the EEA, UK and Switzerland

If data-protection laws of the European Economic Area, the United Kingdom or Switzerland apply to you, we process your personal information on the following legal bases: to perform a contract with you or take steps at your request before entering into one; for our legitimate interests in operating and securing our business and the Site, communicating with business contacts, improving our services and defending legal claims, where those interests are not overridden by your rights; to comply with legal obligations; and, where required, with your consent, which you may withdraw at any time.

You may have the right to access, correct, delete, restrict or object to our processing of your personal information (including objecting at any time to direct marketing), to data portability, and to withdraw consent. To exercise these rights, contact us as described in Section 10.3. You also have the right to lodge a complaint with your local data-protection supervisory authority.

14.How we use artificial intelligence

We use artificial-intelligence tools in our work, for example to help read and answer email, draft documents, write and test software, and carry out requests our clients send us. When we do:

• we share with an AI service only the information needed for the task;
• we use AI services that are not permitted to use what we send them to train their models;
• we never use our clients' data, or messages our clients send us, to train artificial-intelligence models; and
• people at Liberty remain responsible for the work, and we review AI-assisted work that matters before relying on it.

AI tools can make mistakes. If you think a reply or other work from us is wrong, tell us at hello@libertymarketplaces.com and we will look at it.

15.Do Not Track and Global Privacy Control

The Site does not use advertising cookies, cross-site tracking or third-party analytics, so it does not track you across other websites and does not sell or share personal information for targeted advertising. Because of this, the Site does not change its behavior in response to “Do Not Track” browser signals. Where the law requires us to honor an opt-out preference signal, such as Global Privacy Control, we treat it as a request to opt out of any sale or sharing of your personal information, which we do not do in any case.

16.Changes to this policy

We may update this policy from time to time. We will post the updated version on this page and change the “Last updated” date above. If we make material changes, we will give more prominent notice, such as a notice on the Site or an email to our clients, before the changes take effect where the law requires. Earlier versions are available on request.

17.Contact us

If you have questions about this policy or our privacy practices, or want to exercise your rights, contact us:

Please include “Privacy” in the subject line so your message reaches the right person quickly.