Liminal Privacy and Data Protection Policy

This Privacy and Data Protection Policy describes the policies and procedures of First Answer Pte. Ltd. (“First Answer”, "Liminal", "Company", “we”, “our” or “us”) regarding our collection, use and disclosure of your information in connection with your access and use of “lmnl.app” and all of its subdomains (individually referred to as “Site” and collectively referred to as “Sites”), our mobile application for iOS and Android (the “App”), and the other services, features, products, content or applications offered by Liminal (together with the Site and the App, the “Services”).

As used in this Privacy and Data Protection Policy, “Personal Data” means any information that can be used to individually identify a person. All defined terms not defined herein shall have the meaning ascribed to them in the Terms of Use, of which this Privacy and Data Protection Policy is a part.

We urge you to read this Privacy and Data Protection Policy in full, but wanted to mention a few things upfront:

This Privacy and Data Protection Policy covers our treatment of Personal Data that we collect about you

(a) from you directly, when you register for and use your Account on the Services;

(b) from your web browser and/or device, as you interact with the Services generally; and

(c) from third party websites and services, including our business partners and service providers.

In this Privacy and Data Protection Policy, we describe the various purposes for which we use your Personal Data, as well as the legal bases supporting those purposes. As you’ll read below, the legal basis on which we rely for a given use of your Personal Data may be contractual necessity (i.e., where we need to use your Personal Data to complete a contract with you), consent (which you must freely give us, and which you can withdraw at any time), and/or certain legitimate business interests of ours or of others, but only where we have determined that those interests are not overridden by your own interests, rights, and freedoms.

The Services are hosted and operated in various geographic regions through us and certain of our service providers. By using the Services, you acknowledge that any Personal Data you provide to us will be hosted on servers in various geographic regions.

If you are using the Services in the European Economic Area, you may have certain rights regarding the Personal Data we collect from you, under the European Union General Data Protection Regulation (“GDPR”), as outlined below, and for purposes of the GDPR, Liminal would be a controller of Personal Data collected from you through the Services. If you have any questions about this Privacy and Data Protection Policy or whether any of the following applies to you, please contact us directly at [email protected] or at 30 Cecil Street, #19-08 Prudential Tower, Singapore 049712, if you have any questions or concerns about our collection and use of your Personal Data.

As noted in our Terms of Use, we do not knowingly collect or solicit Personal Data from anyone under the age of 18. If you are under the age of 18, you are not allowed to use the Services, so please do not access or use the Site or the App, or attempt to send us any Personal Data. If we confirm that we have collected Personal Data from an individual under the age of 18, we will delete that information as quickly as possible.

This Privacy and Data Protection Policy does not apply to the practices of third parties that we do not own or control, including, but not limited to, any third party websites, services, products or applications (each a “Third Party Service”) that you elect to access and may interact with during your use of the Services, or to individuals that we do not manage or employ. We take steps to ensure that we only work with Third Party Services that share our respect for your privacy, although we cannot take responsibility for the content, products, services or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.

What Does This Privacy and Data Protection Policy Cover?

This Privacy and Data Protection Policy covers our processing of Personal Data that we gather when you are accessing and using the Services. As used in this Privacy and Data Protection Policy, “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.

This Privacy and Data Protection Policy also covers our treatment of any Personal Data that our business partners and service providers share with us, or that we share with our business partners and service providers.

This Privacy and Data Protection Policy does not apply to the practices of third parties, and their sites, services or applications that we do not own or control, or to individuals that we do not employ or manage (“Third Parties”). While we attempt to provide access only to those Third Parties that share our respect for your privacy, we cannot take responsibility for the content, actions or data protection policies or practices of those Third Parties. We encourage you to carefully review the data protection policies and practices of any Third Parties you access, and to carefully consider what kind of Personal Data you choose to post or otherwise make available through the Services.

What Personal Data does Liminal Collect from You?

We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.

By providing Personal Data of others to us, you represent that you have authority to do so. We disclaim responsibility for the information of others that you provide to us in the course of your use of the Services.