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Effective Date: June 16, 2026
Last Updated: June 16, 2026
Company: Liber21, Inc. (hereinafter "Company", "We", "Us", "Our")
EIN: 99-3335614
Address: 16807 Camfield Dr., Moseley, VA 23120, USA
Privacy Contact Email: privacy@liber21.com (or 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 User (Caller) or a Recipient (Called Party), we collect the following data:
| Category | Specific Data | Caller | Recipient |
|---|---|---|---|
| Identifiers | Full name (as it appears on your bank card or government ID) | ✅ | ✅ |
| Email address | ✅ (optional) | ✅ (required for payouts) | |
| Postal address (physical) | ❌ | ✅ (for tax forms) | |
| Telephone number (used for calls) | ✅ | ✅ | |
| Payment Data | Tokenized bank card data (card number, expiration date – stored in tokenized form by PCI‑compliant processor; CVV never stored) | ✅ | ❌ |
| Payout information (bank account number, PayPal address) – only if you provide it | ❌ | ✅ (by your choice) | |
| Technical Data | IP address (when visiting the website and when making/receiving calls) | ✅ | ✅ |
| Service Usage Data | Call data: duration (seconds/minutes), start and end time, date, rate applied, connection status (successful/disconnected) | ✅ | ✅ |
| Cookies and Similar Technologies | Session identifiers, authentication settings, analytics data (Google Analytics – see Section 6) | ✅ | ✅ |
We DO NOT collect:
- Content (audio, text) of telephone conversations.
- Biometric, genetic, or precise geolocation data (other than approximate IP address).
- Data from minors (persons under 18 years of age). The Service is not intended for individuals under 18.
2. Purposes of Processing Personal Data
We use your data solely for the following purposes (based on contract performance, legal obligations, and our legitimate interests):
| Purpose | Data Categories | Legal Basis (under VCDPA) |
|---|---|---|
| Operating the Service: call connection, billing, automatic debits and payouts | Name, phone, email, payment tokens, call data | Performance of contract (Terms of Service) |
| Processing payments (charging Callers, paying Recipients) through our payment processor | Card tokens / bank account data, amount, transaction ID | Performance of contract |
| Fraud prevention and abuse detection (analysis of anomalous calls, IP addresses) | IP, call data, phone number | Legitimate interest (security) |
| Compliance with U.S. tax laws (issuing Form 1099-NEC, tax withholding) | Name, address, SSN/ITIN (Recipients only) | Legal obligation (IRS) |
| Service improvement (analytics of call durations, drop rates) | Anonymized call data, aggregated statistics | Legitimate interest (product development) |
| Sending transactional notifications (SMS, email about calls, charges, payouts) | Name, phone, email | Performance of contract |
| Responding to support requests and data subject rights requests | All categories as necessary | Legitimate interest / contract |
We do NOT use your data for marketing, retargeting, sale to third parties, or profiling that produces legal or similarly significant effects.
3. Disclosure of Personal Data to Third Parties
We disclose your personal data only to the following categories of recipients, and only to the extent necessary for the stated purposes:
| Recipient | Data Disclosed | Purpose | Caller / Recipient |
|---|---|---|---|
| Payment Processor (e.g., Stripe, Braintree, PayPal, ACH provider) | Tokenized card number (for Caller) or bank account/PayPal data (for Recipient), amount, transaction ID | Charging for calls / paying out earnings | Both |
| Telecommunications Carriers (VoIP providers, trunks) | Telephone numbers of both parties, call duration, timestamps, IP address (for routing) | Establishing and maintaining telephone connections, per-minute billing | Both |
We DO NOT disclose your data to:
- Advertising networks or marketing platforms.
- Data brokers.
- Third-party analytics services (other than Google Analytics, but with IP anonymization – see Section 6).
- Any other third parties without your separate consent or a legal requirement.
Exception: If required by lawful request (subpoena, court order, law enforcement demand), we may disclose your data. We will notify you unless prohibited by law.
4. Cookies and Similar Technologies
Our website https://liber21.com uses cookies.
4.1. Types of cookies used:
- Strictly necessary cookies – for authentication, security, session persistence. The website cannot function properly without them.
- Analytics cookies (Google Analytics) – to collect anonymized statistics about visits, actions on the site, response times. We use IP anonymization (the
_anonymizeIpfunction).
4.2. Data collected via cookies:
- IP address (truncated, not sufficient to identify a specific device).
- Browser type, operating system, screen resolution.
- Pages you visit, time of visit, referrer.
4.3. Managing cookies:
You may disable cookies in your browser settings. However, this may prevent you from logging into your account or using certain features. You may also install a browser extension that blocks Google Analytics.
Legal basis for cookies: Legitimate interest (functionality and improvement) under U.S. law (no explicit consent required as under GDPR, but we provide notice via a banner on first visit).
5. Data Retention and Deletion
| Data Type | Retention Period |
|---|---|
| Identifiers (name, phone, email, address) | Duration of account + 3 years after closure to comply with tax and accounting requirements |
| Tokenized bank card data (Caller) | As long as card is linked to account or until account closure. When card is removed, token is revoked within 30 days |
| Payout information (bank account, PayPal) (Recipient) | Duration of account + 3 years |
| Tax information (SSN/ITIN) (Recipient) | 7 years after last tax year (IRS recommendation) |
| Call data (duration, time, rate, phone numbers) | 12 months (to resolve billing disputes) |
| IP addresses and cookie data | 26 months for Google Analytics (with auto‑anonymization), 30 days for server logs |
| Call content | NOT COLLECTED, NOT STORED |
Deletion request: You may send a request to privacy@liber21.com. We will delete your data within 15 business days, except where we are required by law to retain it (tax records, transaction logs). After deletion, you will no longer be able to use the Service.
6. Your Rights (Under VCDPA and Virginia Law)
If you are a resident of the Commonwealth of Virginia, you have the following rights regarding your personal data:
| Right | Description | How to Exercise |
|---|---|---|
| Right to Access | Obtain confirmation of whether we process your data and receive a copy in a portable format | Request to privacy@liber21.com |
| Right to Correct | Correct inaccurate or incomplete data | Request with specific corrections |
| Right to Delete | Delete your personal data unless we have a legal basis to retain it | Deletion request |
| Right to Data Portability | Receive your data in a structured, machine‑readable format (e.g., JSON) | Request specifying format |
| Right to Opt Out | Opt out of processing for targeted advertising, sale of data, or profiling (we do not engage in such activities, but you may opt out of analytics cookies via browser settings) | Browser settings or request |
| Right to Appeal | If we deny your request, you may appeal within 45 days | Reply to our denial notice |
How to submit a request:
Send an email to privacy@liber21.com with the subject line "Data Subject Request – Virginia". Include your name, phone number used with the Service, and the specific right you wish to exercise. We will verify your identity (we may request additional information) and respond within 15 business days (up to 45 days for complex requests).
Appeals: If your request is denied, you may write to the same address with "Appeal" in the subject line within 30 days. We will review the appeal and provide a written response. If you remain unsatisfied, you may file a complaint with the Virginia Attorney General:
https://www.oag.state.va.us/consumer-protection/
7. Security of Personal Data
We implement the following security measures:
- TLS 1.3 encryption for data transmission between your browser and our website.
- Card data tokenization through a PCI DSS Level 1 certified payment processor.
- Limited access – only authorized employees who have undergone security training may access personal data.
- Regular software updates and intrusion monitoring.
- Password policy for Recipient accounts (hashed and salted storage).
Nevertheless, no method of transmission over the Internet is 100% secure. We do not guarantee absolute security, but we make reasonable efforts.
In the event of a data breach that creates a risk to your rights, we will notify you and the relevant authorities within 72 hours (as required by Virginia law).
8. Children (Minors Under 18)
Our Service is not intended for individuals under 18 years of age. We do not knowingly collect personal data from minors. If you become aware that a child has provided us with data, please contact us, and we will delete it immediately. The prohibition on use by minors is also set forth in our Terms of Service.
9. Cross-Border Data Transfers
All data is processed on servers located in the United States of America. If you are located outside the U.S., your data will be transferred to the U.S. U.S. law may not provide the same level of protection as the laws of your country. By using the Service, you consent to such transfer. Cross-border transfers are governed by U.S. federal law and Virginia law, not GDPR.
10. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. If we make material changes (e.g., new categories of data, new recipients), we will notify you by email or SMS at least 30 days before the changes take effect. We will also post the new version on our website. Your continued use of the Service after the effective date constitutes your acceptance of the updated Privacy Policy.
11. Contact for Questions and Requests
If you have questions, complaints, or wish to exercise your rights, contact us:
By email: privacy@liber21.com (preferred) or finance@liber21.com
By mail: Liber21, Inc., 16807 Camfield Dr., Moseley, VA 23120, USA
Response time: 15 business days (for complex requests – up to 45 days with notice of extension).
12. Complaints to Regulatory Authorities
You may file a complaint with the Virginia Attorney General:
https://www.oag.state.va.us/consumer-protection/
You may also file a complaint with the Federal Trade Commission (FTC) through its Complaint Assistant.
Thank you for using the LIBER Service. We value your trust.