This Privacy Notice summarises how Liquidity Fintech FZE ("LTP UAE", "we", "us") collects, uses and protects personal data in accordance with:
- UAE Federal Decree-Law No. (45) of 2021 on the Protection of Personal Data ("PDPL"); and
- Applicable regulations and guidance issued by the Dubai Virtual Assets Regulatory Authority ("VARA").
This Notice applies to individuals who interact with LTP UAE, including clients, prospective clients, counterparties, authorised representatives, and website users.
1. Personal Data We Collect
We may collect personal data including identification and KYC information, contact details, financial and transactional data, compliance and risk information (including AML/CFT screening), technical data (such as IP address and device information), and communications with us.
Failure to provide required information may prevent us from onboarding you or providing services.
2. How We Use Personal Data
Personal data is processed for purposes including:
- Client onboarding, identity verification and investor classification;
- AML/CFT, sanctions screening and transaction monitoring;
- Provision and administration of authorised virtual asset services;
- Regulatory reporting and compliance with applicable laws;
- Technology, cybersecurity, risk management and operational purposes;
- Communications and relationship management.
3. Legal Basis for Processing
We process personal data based on one or more lawful bases under the PDPL, including compliance with legal and regulatory obligations, performance of a contract, legitimate interests, and consent where required.
4. Disclosure and Third Parties
We may share personal data, on a need-to-know basis, with:
- VARA and other competent regulators or authorities;
- Banks, custodians, exchanges and liquidity providers;
- AML/CFT, KYC, blockchain analytics and technology service providers;
- Professional advisers and group entities.
All recipients are subject to appropriate confidentiality and data protection obligations.
5. International Transfers and Cross-Border Processing
Personal data may be transferred to, stored or processed in jurisdictions outside the UAE, where this is necessary for operational, compliance or group-level purposes.
We take reasonable steps to ensure appropriate contractual, technical and organisational safeguards are in place in accordance with PDPL and VARA requirements.
For clients onboarded on a reverse-solicitation basis or accessing our services from outside the UAE, you acknowledge and agree that:
- Personal data may be processed in jurisdictions that do not provide the same level of data protection as your country of residence or incorporation;
- LTP UAE processes personal data primarily in accordance with UAE law and applicable VARA requirements; and
- It is your responsibility to assess whether the processing, storage or transfer of personal data complies with any laws applicable to you in your home jurisdiction, and to obtain any necessary consents or approvals required under such laws.
By accessing or using our services, you expressly accept the risks associated with cross-border data transfers and processing.
6. Data Retention and Security
Personal data is retained only for as long as necessary to fulfil legal, regulatory and operational requirements. We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss or misuse.
7. Your Rights
Subject to applicable law, you may request access to, correction of, or restriction on the processing of your personal data. Certain rights may be limited where required to comply with regulatory obligations.
8. Contact Us
Liquidity Fintech FZE
Floor 23, Unit EO44 SRT, Sheikh Rashid Tower
Dubai World Trade Centre, Sheikh Zayed Road
Dubai, United Arab Emirates
DPO Email: [email protected]