PRIVACY NOTICE

Last updated: 25 June 2026Effective date: 1 July 2026

PRIVACY NOTICE

1. This Privacy Notice explains how LIQUIDITY TECHNOLOGY LIMITED, Registration No. 2070972, of Jayla Place, 2nd Floor, Road Town, Tortola, British Virgin Islands, and any LTL related entitles listed in Schedule 1, collects, uses, stores, discloses, transfers and protects personal data.

2. In this Notice, "LTL", "we", "us" or "our" means LTL.

3. "Personal Data" means any information relating to an identified or identifiable individual. This includes similar terms used in different jurisdictions, including personal information, personal data, sensitive personal data, sensitive personal information, consumer personal information and personally identifiable information.

4. This Notice is intended to apply in the following jurisdictions: British Virgin Islands, Singapore, Australia, United Arab Emirates, United States and Hong Kong. Where local law gives you additional rights, those rights apply in addition to this Notice.

SCOPE

1. This Notice applies to personal data that LTL processes about:

customers, users, clients and prospective customers;
website visitors and app users;
business contacts, suppliers, service providers and professional advisers;
event attendees, marketing contacts and newsletter subscribers;
job applicants, unless a separate recruitment privacy notice applies; and
any other individual who provides personal data to LTL or whose personal data is provided to LTL.

2. Where LTL processes personal data on behalf of another organization, such as a client, customer or business partner, LTL may act as a processor, service provider or data intermediary. In those cases, the other organization's privacy notice may also apply.

PERSONAL DATA

1. LTL may collect the following categories of personal data:

Identity and contact data: name, title, date of birth, nationality, employer, job title, postal address, email address, telephone number, username and account details.
Business and transaction data: client number, order history, service history, billing details, payment details, delivery information, invoices, contract records and communications with LTL.
Verification and compliance data: identity documents, proof of address, sanctions screening results, anti-money laundering or know-your-customer information, tax information, regulatory records and audit records.
Technical and usage data: IP address, device identifiers, browser type, operating system, log data, cookie identifiers, website usage, app usage, pages viewed, session activity and approximate location.
Marketing and preference data: marketing preferences, communication preferences, event attendance, survey responses, feedback and campaign engagement.
Support and communications data: emails, calls, messages, complaints, enquiries, notes of meetings and records of interactions with LTL.
Recruitment data: CV, employment history, education history, references, interview notes, background screening information and right-to-work information.
Sensitive data: where necessary and lawful, LTL may collect sensitive personal data, such as government identifiers, financial information, health-related information, biometric information, criminal record information, racial or ethnic origin, religious or philosophical beliefs, trade union membership or other sensitive information. LTL will only collect sensitive data where required or permitted by law, with consent where required, or where necessary for a permitted purpose.

2. LTL does not intend to collect personal data from children. If LTL becomes aware that it has collected personal data from a child without required parental or guardian consent, LTL will take reasonable steps to delete or de-identify that data, unless retention is required or permitted by law.

HOW WE COLLECT PERSONAL DATA

1. LTL may collect personal data:

directly from you, including when you complete forms, create an account, contact us, use our services, attend events, apply for a role or subscribe to communications;
automatically through websites, apps, cookies, analytics tools, security logs and similar technologies;
from clients, customers, business partners, employers, advisers, agents and representatives;
from payment processors, identity verification providers, screening providers, analytics providers, advertising partners and other service providers;
from public sources, including public registers, company registries, professional directories, websites, social media and public databases; and
from regulators, authorities, courts, tribunals or law enforcement agencies, where lawful.

WHY WE USE PERSONAL DATA

1. LTL may use personal data for the following purposes:

to provide, operate, administer and improve LTL's products, services, websites, apps and platforms;
to register, manage and authenticate accounts;
to process orders, payments, invoices, refunds and transactions;
to communicate with you, respond to enquiries and provide support;
to manage client, supplier, partner and professional relationships;
to conduct verification, due diligence, anti-fraud, sanctions, anti-money laundering and other compliance checks;
to comply with legal, regulatory, tax, accounting, audit, reporting and recordkeeping obligations;
to protect LTL, our systems, our users and third parties from fraud, cyber threats, misuse, unauthorized access and unlawful activity;
to conduct analytics, quality assurance, product development, training, testing and business improvement;
to send marketing communications, newsletters, event invitations, updates and other promotional content, where permitted by law;
to personalize website, app, service and marketing experiences, where permitted by law;
to manage recruitment, applications, interviews, assessments, background screening and onboarding;
to enforce contracts, protect legal rights, manage disputes and obtain legal advice;
to support mergers, acquisitions, restructuring, financing, asset sales, transfers of business or similar transactions; and
for any other purpose notified to you, authorized by you or permitted by law.

Legal basis or legal ground for processing

1. Where LTL is required to rely on a legal basis or legal ground, LTL may rely on one or more of the following, to the extent available under applicable law:

your consent;
performance of a contract with you or steps taken at your request before entering a contract;
compliance with legal or regulatory obligations;
LTL's legitimate interests, where recognized by applicable law and not overridden by your rights;
protection of vital interests;
establishment, exercise or defence of legal claims;
public interest or administration of justice, where applicable;
deemed consent, business improvement, legitimate interests or other statutory exceptions, where available under applicable law; and
any other lawful basis or exception permitted by applicable law.

2. Where consent is required, you may withdraw consent at any time by contacting LTL. Withdrawal of consent does not affect processing that occurred before withdrawal, or processing that LTL may continue under another lawful basis.

WHEN PERSONAL DATA IS REQUIRED

1. Some personal data is voluntary. Some personal data is required because LTL needs it to provide services, comply with law, verify identity, process transactions, manage security or perform a contract.

2. If you do not provide required personal data, LTL may be unable to provide certain services, open or maintain an account, process a transaction, respond to a request, consider an application, or comply with legal obligations.

WHO WE DISCLOSE PERSONAL DATA TO

1. LTL may disclose personal data to:

LTL group companies and affiliates;
service providers, vendors, contractors and processors, including hosting providers, cloud providers, IT support providers, payment processors, analytics providers, marketing platforms, customer support tools, identity verification providers, screening providers and professional service providers;
banks, payment networks, insurers, auditors, lawyers, accountants and other professional advisers;
clients, customers, business partners, agents, representatives and counterparties, where necessary for the relevant relationship or transaction;
regulators, courts, tribunals, government agencies, law enforcement agencies and public authorities;
third parties involved in mergers, acquisitions, financing, restructuring, due diligence, asset sales, insolvency, business transfers or similar transactions;
advertising, analytics and social media partners, where permitted and subject to your choices; and
any other person where you have authorized disclosure or where disclosure is required or permitted by law.

2. LTL requires service providers and processors to protect personal data and use it only for authorized purposes.

INTERNATIONAL TRANSFERS

1. LTL may process and transfer personal data in and to the following countries or territories: [insert countries, e.g. BVI, Singapore, Australia, UAE, United States, Hong Kong, United Kingdom, European Economic Area, India, Philippines].

2. Where LTL transfers personal data internationally, LTL will use appropriate safeguards where required, which may include contractual protections, transfer agreements, standard contractual clauses, adequacy decisions, consent, necessity for contract performance, or other mechanisms permitted by applicable law.

RETENTION

1. LTL retains personal data for as long as reasonably necessary for the purposes described in this Notice, including to provide services, manage relationships, comply with legal obligations, resolve disputes, enforce agreements, maintain security and keep appropriate business records.

2. Retention periods may vary depending on:

the type and sensitivity of the data;
the purpose for which it was collected;
legal, regulatory, tax, accounting and limitation-period requirements;
the existence of actual or potential disputes;
operational and security needs; and
whether the data can be deleted, anonymized or de-identified.

3. When personal data is no longer required, LTL will delete, anonymize, de-identify or securely retain it in accordance with applicable law and internal retention policies.

COOKIES AND SIMILAR TECHNOLOGIES

1. LTL may use cookies, pixels, tags, SDKs, local storage and similar technologies to operate websites and apps, remember preferences, secure services, analyze usage, measure performance and deliver or measure advertising.

2. LTL may use:

strictly necessary cookies for security, authentication, fraud prevention and service functionality;
analytics cookies to understand service usage and improve performance;
preference cookies to remember settings; and
advertising cookies to deliver, personalize or measure advertising, where permitted.

3. Where required by law, LTL will obtain consent before using non-essential cookies. You may manage cookie choices, browser settings or legally recognized opt-out signals, where applicable.

MARKETING

1. LTL may send marketing communications where permitted by law. You may opt out of marketing emails by using the unsubscribe link or contacting LTL.

2. LTL will not use your personal data for direct marketing where consent is required unless LTL has obtained the required consent or indication of no objection.

3. LTL will respect applicable direct marketing, telephone, SMS, email, Do Not Call, anti-spam and opt-out requirements.

SALE, SHARING AND TARGETED ADVERTISING

1. LTL does not sell personal data, share personal data for cross-context behavioral advertising, or process personal data for targeted advertising as those terms are defined under applicable U.S. state privacy laws.

2. LTL does not knowingly sell or share personal data of children under 16 without legally required opt-in consent.

AUTOMATED DECISION-MAKING AND PROFILING

1. LTL may use automated tools such as AI bots, Telegram bots to support security, fraud prevention, account authentication, service personalization, analytics, compliance screening and operational efficiency.

2. LTL will not make solely automated decisions that produce legal or similarly significant effects unless permitted by law and subject to required notices, rights and safeguards.

3. Where applicable, you may have the right to object to, opt out of, or request human review of certain automated decisions or profiling.

SECURITY

1. LTL uses reasonable technical, organizational and administrative measures designed to protect personal data against unauthorized access, loss, misuse, alteration, disclosure or destruction.

2. Security measures may include access controls, encryption, logging, monitoring, staff training, confidentiality controls, vendor due diligence, secure transfer methods and incident response processes.

3. No system is completely secure. LTL cannot guarantee absolute security of personal data.

YOUR RIGHTS

1. Depending on your jurisdiction, you may have rights to:

request access to personal data LTL holds about you;
request information about how LTL collects, uses, discloses, sells, shares or transfers your personal data;
request correction of inaccurate or incomplete personal data;
request deletion or erasure of personal data;
request restriction or cessation of processing;
object to certain processing;
withdraw consent;
request portability or transfer of personal data;
opt out of direct marketing;
opt out of sale, sharing, targeted advertising or certain profiling, where applicable;
limit use or disclosure of sensitive personal data, where applicable;
appeal LTL's decision on a privacy request, where applicable; and
lodge a complaint with LTL or a relevant regulator.

2. To exercise rights, contact LTL using the details in section 20.

3. LTL may need to verify your identity before responding. LTL may refuse, limit or charge a fee for requests where permitted by law, including where a request is unfounded, excessive, repetitive, legally privileged, affects another person's rights or conflicts with legal obligations.

4. LTL will not discriminate against you for exercising privacy rights.

COMPLAINTS

1. If you have concerns about LTL's handling of personal data, contact LTL first using the details in section 20.

2. You may also have the right to complain to a privacy regulator or data protection authority in your jurisdiction.

THIRD-PARTY LINKS AND SERVICES

1. LTL websites, apps or communications may contain links to third-party websites, apps, platforms or services.

2. LTL is not responsible for the privacy practices of third parties. You should review their privacy notices before providing personal data to them.

CHANGES TO THIS NOTICE

1. LTL may update this Notice from time to time.

2. The updated Notice will be posted here. Where required by law, LTL will provide additional notice or obtain consent for material changes.

CONTACT LTL

1. For privacy questions, requests or complaints, contact:

Title: Data Protection Officer/Privacy Contact

Email: [email protected] or [email protected]

JURISDICTION-SPECIFIC ADDENDUM

1. Set out below are the jurisdiction specific addendum for the LTP related entities and the paragraphs set out the differences in treatment for Personal Data (non-exhaustive).

BRITISH VIRGIN ISLANDS

1. Where BVI data protection law applies, LTL will inform you, where required, of:

the purposes for which personal data is collected and processed;
any available information about the source of the personal data;
your rights to request access to and correction of personal data;
how to contact LTL about privacy enquiries or complaints;
the classes of third parties to whom LTL discloses or may disclose personal data;
whether providing personal data is voluntary or obligatory; and
the consequences of not providing obligatory personal data.

2. Where LTL relies on consent, you may withdraw consent, subject to applicable law.

3. Where LTL transfers personal data outside the BVI, LTL will use appropriate safeguards or obtain consent where required.

SINGAPORE

1. Where Singapore's PDPA applies, LTL will notify you of the purposes for which it collects, uses or discloses personal data on or before such collection, use or disclosure, unless an exception applies.

2. You may request access to or correction of your personal data, and you may withdraw consent by contacting LTL.

3. LTL's Singapore Data Protection Officer contact is: [email protected]

4. LTL will comply with applicable Singapore Do Not Call and marketing requirements.

AUSTRALIA

1. Where the Australian Privacy Act and Australian Privacy Principles apply, LTL will take reasonable steps to notify you of collection matters, including LTL's identity and contact details, the circumstances of collection, the purposes of collection, usual disclosures, access and correction rights, complaint process and likely overseas disclosures.

2. LTL is likely to disclose personal information to overseas recipients in: [insert countries if practicable].

3. You may complain to LTL using the contact details in section 20. If unresolved, you may have the right to complain to the Office of the Australian Information Commissioner.

UNITED ARAB EMIRATES

1. Where UAE federal personal data protection law applies, LTL will provide information required by law, including purposes of processing, categories of personal data, sharing inside or outside the UAE, retention criteria, cross-border transfer safeguards, rights procedures, complaint procedures and breach-related information where required.

2. You may have rights to receive information, access, correction, erasure, restriction, cessation of processing, portability, objection to direct marketing and objection to certain automated processing.

3. If LTL operates in or processes personal data through DIFC or ADGM, separate DIFC or ADGM privacy terms may also be required and you may locate such privacy terms from the website of our UAE entity.

HONG KONG

1. Where Hong Kong's PDPO applies, LTL will provide a personal information collection statement where required, including:

the purpose for which personal data is collected;
the classes of persons to whom personal data may be transferred;
whether provision of personal data is obligatory or voluntary;
consequences of not providing required personal data; and
your rights to request access to and correction of personal data.

2. LTL will not use personal data for a new purpose unless the new purpose is directly related to the original purpose or LTL has obtained prescribed consent where required.

3. LTL will comply with applicable Hong Kong direct marketing requirements.

LIST OF LTL RELATED ENTITIES

1. LTL related entities covered under this Privacy Notice includes:

Name:	Address:
Liquidity Fintech Investment Limited	Aegis Chambers, 1st Floor, Ellen Skelton Building, 3076 Sir Francis Drake's Highway, Road Town, Tortola, British Virgin Islands
Liquidity Fintech Limited	Jayla Place, 2nd Floor, Road Town, Tortola, British Virgin Islands
LiquidityTech Limited	SUITE 2808, 28/F TWO EXCHANGE SQUARE, 8 CONNAUGHT PLACE, CENTRAL, HONG KONG
Neutrium Trust Limited	SUITE 2808, 28/F TWO EXCHANGE SQUARE, 8 CONNAUGHT PLACE, CENTRAL, HONG KONG
Liquidity Fintech Pty Ltd	Suite 302, 13/15 Wentworth Ave, Sydney 2000, New South Wales, Australia
LiquidityTech Pty Ltd	Suite 302' Unit 13, 13-15 Wentworth Avenue , Sydney NSW 2000
Liquidity Fintech FZE	Floor23, Unit FO44 SRT, Sheikh Rashid Tower, Dubai World Trade Centre, Sheikh Zayed Road, Dubai, United Arab Emirates