Privacy Policy

Last updated: January 16, 2025

This Privacy Policy describes how Liquidity AI Corp ("Company," "We," "Us," or "Our") collects, uses, discloses, and protects information in connection with Your access to and use of the Donna AI platform and related services (the "Service"). This Policy applies to visitors, clients, prospective investors, and other individuals whose information We process in connection with the Service.

As a broker-dealer registered with the U.S. Securities and Exchange Commission ("SEC") and a member of the Financial Industry Regulatory Authority ("FINRA"), We are also subject to the privacy and safeguarding requirements of SEC Regulation S-P, in addition to applicable state privacy laws. Where a conflict exists between this Policy and Regulation S-P or other applicable securities regulations, the securities regulation shall control.

Information We Collect

We may collect the following categories of information:

  • Identifiers, such as name, email address, phone number, mailing address, and IP address.

  • Professional and Business Information, such as company name, job title, investment criteria, deal history, and investment decks submitted through the Service.

  • Financial Information, such as billing details and payment information processed through Our third-party payment processors.

  • Nonpublic Personal Information ("NPI"), as defined under Regulation S-P, which may be collected in connection with brokerage or investment banking services provided under a separate Engagement Agreement.

  • Usage Data, such as browser type, pages visited, time spent on the Service, referring URLs, and device identifiers, collected automatically through cookies and similar technologies.

  • Communications Data, including the content of emails, voice interactions, and messages processed through Our AI agents, outreach automation, and voice assistant features.

How We Use Your Information

We use the information We collect to:

  • Provide, operate, and maintain the Service, including AI-driven data enrichment, outreach automation, and voice agent features;

  • Facilitate investment banking, deal sourcing, and capital markets activities under an applicable Engagement Agreement;

  • Communicate with You regarding Your account, transactions, and customer support inquiries;

  • Comply with applicable legal, regulatory, and recordkeeping obligations, including those under FINRA Rule 4511 and SEC Rule 17a-4;

  • Detect, investigate, and prevent fraud, unauthorized access, and other harmful activity; and

  • Improve and train Our AI models and platform performance, using de-identified or aggregated data where feasible.

Legal Basis and Consent

We process Your information based on Our legitimate business interests, Your consent where required, performance of a contract with You, and compliance with applicable legal and regulatory obligations, including those imposed by FINRA and the SEC.

How We Share Your Information

We do not sell Your personal information for monetary consideration. We may share information with:

  • Service Providers, including cloud hosting, data enrichment, analytics, and outreach platform providers (such as Outreach.io), who are contractually obligated to protect Your information;

  • Regulators and Legal Authorities, including the SEC, FINRA, and other governmental or regulatory bodies, as required by law or in connection with regulatory examinations;

  • Professional Advisors, including legal, accounting, and compliance consultants; and

  • Successors, in connection with a merger, acquisition, financing, or sale of all or a portion of Our business, subject to applicable confidentiality protections.

Regulation S-P Safeguarding and Opt-Out Rights

Consistent with Regulation S-P, We do not disclose Your nonpublic personal information to unaffiliated third parties for their own independent marketing purposes, except as permitted by law. Where required, You will be provided with an opportunity to opt out of certain disclosures of Your NPI to non-affiliated third parties. We maintain administrative, technical, and physical safeguards reasonably designed to protect the confidentiality and security of Your NPI.

Your California Privacy Rights (CCPA/CPRA)

If You are a California resident, You have the right to:

  • Know what personal information We collect, use, and disclose about You;

  • Request deletion of Your personal information, subject to certain exceptions, including information We are required to retain under FINRA and SEC recordkeeping rules;

  • Correct inaccurate personal information;

  • Opt out of the sale or sharing of Your personal information, to the extent applicable;

  • Limit the use and disclosure of sensitive personal information; and

  • Not be discriminated against for exercising any of these rights.

To exercise these rights, please contact Us using the information provided in the "Contact Us" section below. We will verify Your request in accordance with applicable law before taking action.

Cookies and Tracking Technologies

We use cookies, web beacons, and similar tracking technologies to operate and improve the Service, analyze usage patterns, and support outreach and marketing functions. You may control cookie preferences through Your browser settings; however, disabling cookies may affect the functionality of the Service.

Data Retention

We retain personal information, including communications and transaction-related records, for as long as necessary to fulfill the purposes described in this Policy and to comply with applicable legal, regulatory, and recordkeeping obligations, including the retention periods mandated by FINRA Rule 4511 and SEC Rule 17a-4.

Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect Your information from unauthorized access, disclosure, alteration, or destruction. However, no method of transmission or storage is completely secure, and We cannot guarantee absolute security.

International Data Transfers

Your information may be transferred to, stored, and processed in the United States or other jurisdictions where Our service providers operate. We take reasonable steps to ensure Your information receives an adequate level of protection in the jurisdictions in which it is processed.

Children's Privacy

The Service is intended for business and institutional use and is not directed to individuals under the age of 18. We do not knowingly collect personal information from children.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify You of material changes by posting the updated Policy on this page and updating the "Last updated" date above.

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