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Effective Date: June 10, 2026
Last Updated: June 10, 2026
Company: Liber21, Inc. (hereinafter "Company", "We", "Us", "Our")
EIN: 99-3335614
Address: 16807 Camfield Dr., Moseley, VA 23120, USA
Privacy Contact Email: finance@liber21.com
Website: https://liber21.com
This Privacy Policy describes what personal data we collect, how we use, store, transfer, and protect your data when you use the LIBER Service (including the website, telephone system, IVR, Caller and Recipient accounts).
Please read this document carefully. By using the Service, you agree to the terms of this Privacy Policy.
1. Categories of Personal Data Collected
Depending on whether you are a Caller or a Recipient, we collect the following categories of personal data:
| Category | Specific Data | Caller | Recipient |
|---|---|---|---|
| Identifiers | Full name | ✅ | ✅ |
| Email address | ✅ (optional) | ✅ (required) | |
| Postal address | ❌ | ✅ (for tax forms) | |
| Telephone number | ✅ | ✅ | |
| Payment Data | Tokenized bank card data | ✅ | ❌ |
| Payout information (bank/PayPal) | ❌ | ✅ (by choice) | |
| Technical Data | IP address | ✅ | ✅ |
| Service Usage Data | Call data (duration, time, rate, status) | ✅ | ✅ |
| Cookies | Session identifiers, analytics | ✅ | ✅ |
We DO NOT collect: content of conversations, biometric, geolocation, or data from minors.
2. Purposes of Processing Personal Data
We use your data only for: operating the Service, processing payments, fraud prevention, tax compliance, service improvement, sending notifications, and responding to support requests. We do NOT use data for marketing, sale to third parties, or profiling.
3. Disclosure of Personal Data to Third Parties
We share data only with:
- Payment Processor – for charging cards and making payouts.
- Telecommunications Carriers – for call routing and billing.
We never sell your data to advertisers or data brokers.
4. Cookies and Similar Technologies
We use strictly necessary cookies (authentication, security) and analytics cookies (Google Analytics with IP anonymization). You can disable cookies in your browser or use the Google Analytics opt-out add-on.
5. Data Retention and Deletion
We retain data as follows: identifiers for account duration + 3 years; call data for 12 months; IP addresses for 30 days. You may request deletion by emailing finance@liber21.com. We will respond within 15 business days.
6. Your Rights (Under VCDPA and Virginia Law)
Virginia residents have the right to access, correct, delete, port their data, opt out of certain processing, and appeal denied requests. To exercise, email finance@liber21.com.
7. Security of Personal Data
We use TLS 1.3 encryption, tokenization, limited access, and regular monitoring. In case of a data breach, we will notify you and authorities within 72 hours.
8. Children (Minors Under 18)
The Service is not intended for individuals under 18. We do not knowingly collect data from minors.
9. Cross-Border Data Transfers
All data is processed on servers in the United States. If you are outside the U.S., your data will be transferred to the U.S., and U.S. law applies.
10. Changes to This Privacy Policy
We may update this policy. Material changes will be notified via email or SMS at least 30 days in advance.
11. Contact Information
Email: finance@liber21.com
Mail: Liber21, Inc., Attn: Privacy Officer, 16807 Camfield Dr., Moseley, VA 23120, USA
Response time: 15 business days
12. Complaints to Regulatory Authorities
You may file a complaint with the Virginia Attorney General or the Federal Trade Commission (FTC).
Thank you for using the LIBER Service. We value your trust.