Website Privacy Notice
Privacy Notice
Effective from 07 Sep 2026
1. Introduction
This Website is owned and operated by First Answer (BVI) Limited. First Answer Panama Inc. and First Answer Canada Inc., are licensed users of the Platform and Website and act as principal counterparty and controller for the OTC Services they provide. These entities trade as “Liminal Prime”. The terms “Visitor”, “User”, “Website”, and the specific Liminal Prime entity you are dealing with, have the meanings given to them in, and are further described in, our Website Visitors Terms and Conditions.
2. Personal Information We Collect
The Personal Information we collect depends on how you interact with us and which Services you use.
Website and general interactions
| When we collect it | What we collect | Why we collect it |
|---|---|---|
| When you visit our Website | Cookies, analytics identifiers, IP address, browser type, device information, pages viewed, timestamps, navigation patterns | Operate and secure the Website; analyze performance and usage; improve user experience |
| When you submit an enquiry or contact form | Name, organization, email address, phone number, assets of interest, estimated monthly volumes, and content of your message | Respond to your enquiry; take steps prior to entering a business relationship |
| When you subscribe to communications | Name, email address, organization name | Send you product news, updates and marketing communications, where permitted |
| When you interact with us at events or on social media | Name, business contact details, public profile information, content of interactions | Follow up on your interest; maintain business relationships |
Onboarding and compliance
| When we collect it | What we collect | Why we collect it |
|---|---|---|
| When onboarding is required | Identity and organizational information necessary to onboard you or your organization as a counterparty or participant, as required by applicable law and our internal policies. | Complete onboarding; meet our legal and regulatory obligations; prevent fraud |
| When we engage in business development | Name, business contact details, job title, employer, professional profile information; information from publicly available sources or trusted third-party data providers | Develop and maintain business relationships; identify organizations that may be interested in our Services |
Account and service use
| When we collect it | What we collect | Why we collect it |
|---|---|---|
| When you create an account | Name, business email address, contact details, role or job title | Create and manage your account; authenticate access; send service communications |
| When you access or use the Services | Account and user profile data; API request metadata and logs, including IP addresses; audit and activity logs; session tokens and authentication data | Provide, operate, secure and audit the Services; authenticate access; investigate incidents |
| When you use our Services | Wallet addresses, bank account details, settlement instructions, and related service records generated through your use of the Services | Enable and support the delivery of the Services; retain records as required by law |
| When you or your organization are billed | Billing contact name and email, payment method details processed by our payment processors | Process payment; issue invoices; comply with financial record-keeping obligations |
Information collected automatically
When you visit our Website or use our Services, we automatically collect technical information about your browser and device, including IP address, browser type, operating system, device type, language preferences, referring URLs, pages viewed, and interaction data. We use this information to operate, secure, and improve the Website and Services, and to protect against fraud and malicious activity.
3. How We Use Personal Information
We use the Personal Information we collect to:
- Provide, operate, maintain and secure the Website and Services;
- Authenticate users, manage accounts, and provide customer and technical support;
- Communicate with you, including responding to enquiries and providing service-related notices;
- Administer our business, including accounting, auditing, reporting, and internal operations;
- Improve and develop the Website and Services and enhance the user experience;
- Conduct business development and marketing activities, where permitted by applicable law;
- Verify identities and fulfil our AML, CTF, and sanctions screening obligations;
- Detect, investigate and prevent fraud, security incidents, and other unlawful activity;
- Comply with applicable laws, regulations, and requests from competent authorities; and
- Establish, exercise or defend legal claims and protect the rights, property, and security of Liminal Prime and others.
Where required by applicable law, we rely on one or more of the following legal bases:
- Performance of a contract or steps taken at your request before entering into a contract;
- Our legitimate interests, provided those interests are not overridden by your rights and freedoms;
- Compliance with a legal obligation; and
- Your consent, where required.
4. How We Share Personal Information
We share Personal Information only where necessary. We may disclose Personal Information to:
- Liminal Prime affiliates
Personal Information may be shared between Liminal Prime affiliates to the extent necessary to provide the Services, fulfil compliance obligations, and support our business operations. - Technology and infrastructure providers
We use third-party technology infrastructure providers, cloud and hosting services, and other IT service providers to operate the Website and Services. These providers process Personal Information on our behalf as data processors under contractual obligations that include purpose limitation, data minimisation, access controls, and deletion or return of data on termination. - Identity verification and compliance providers
Where required, we use specialist third-party providers to support identity verification, counterparty due diligence, AML screening, sanctions checks, and fraud prevention. These providers may act as sub-processors (processing data on our behalf) or as independent controllers (processing data under their own legal obligations and privacy policies). Categories of such providers include identity and business verification services (KYB/KYC), sanctions and watchlist screening services, and blockchain analytics services. - Analytics providers
Where you consent to analytics cookies, certain website usage data is processed by analytics service providers on our behalf. - Payment processors
Payment method details are processed by our payment processors. We do not store full payment card details. - Professional advisers
We may share Personal Information with lawyers, auditors, insurers, and consultants where necessary for advice, compliance, or dispute resolution. - Regulators and law enforcement
We may disclose Personal Information where required or permitted by law, regulation, or requests from competent regulatory, governmental, or law enforcement authorities. Where legally permissible, we will seek to notify you of such disclosure. - Business transfers
In the event of a proposed or completed merger, acquisition, financing, reorganisation, or other corporate transaction, Personal Information may be disclosed to the parties involved, subject to appropriate confidentiality obligations.
We do not sell your Personal Information
5. Automated and AI-Assisted Processing
Liminal Prime uses automated tools and, where applicable, AI-assisted systems to support operational and compliance functions, including analysing activity patterns, supporting sanctions and fraud screening, and maintaining audit trails. Outputs are subject to appropriate human oversight. We do not make decisions based solely on automated processing that produce legal effects concerning you or significantly affect you. Where automated tools inform a decision that may affect you, appropriate human review is available on request.
6. Cookies and Tracking Technologies
Cookies are small text files placed on your device when you visit our Website. We use them for the following purposes:
- Strictly necessary cookies
Required for the Website to function and for basic security. No consent needed. - Analytics cookies
We use Google Analytics to understand how visitors use our Website and to improve its performance. Google may process this data on our behalf; for details, please refer to Google’s privacy documentation. - Managing your preferences
A cookie banner on your first visit lets you accept or reject analytics cookies. You can change your preferences at any time via “Cookie settings” on our Website. We do not use marketing or advertising cookies unless we specifically notify you and provide a choice through our cookie preference centre.
7. Your Rights
Depending on your location and applicable law, you may have the right to:
- Access the Personal Information we hold about you;
- Request correction of inaccurate or incomplete Personal Information;
- Request deletion of your Personal Information, subject to applicable legal exceptions;
- Request restriction of, or object to, certain processing activities;
- Receive Personal Information in a structured, commonly used and machine-readable format, where applicable;
- Withdraw your consent at any time where processing is based on consent; and
- Lodge a complaint with your local data protection or supervisory authority.
To exercise any of these rights, please contact us at [email protected]. We may need to verify your identity before processing your request.
8. Opting Out of Communications
9. Children
Our Website and Services are intended for business users and are not directed to individuals under 18. We do not knowingly collect Personal Information from individuals under 18. If you believe a minor has provided us with Personal Information, please contact us.
10. Security of Personal Information
We maintain appropriate technical and organisational measures to protect Personal Information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. We regularly review and update our security measures to address evolving risks and industry practices.
11. Retention of Personal Information
We retain Personal Information only for as long as necessary to fulfil the purposes described in this Privacy Policy, comply with legal and regulatory obligations, resolve disputes, enforce our agreements, and protect our legitimate business interests. Retention periods vary depending on the nature of the information, the purpose for which it was collected, and applicable legal requirements. Where Personal Information is held by sub-processors or infrastructure providers on our behalf, equivalent retention controls apply.
12. Third-Party Services
Our Website and Services may contain links to, or integrate with, third-party websites, applications, or services not owned or controlled by Liminal Prime. We are not responsible for their privacy practices and encourage you to review their privacy policies before providing any Personal Information.
13. International Transfers
Liminal Prime is a global business and may transfer or make Personal Information accessible to its affiliates and trusted service providers in countries other than the country in which it was collected. Where required by applicable law, we implement appropriate safeguards, including Standard Contractual Clauses or other lawful transfer mechanisms.
14. Privacy Policy Updates
We may update this Privacy Policy from time to time to reflect changes to our business, Services, legal obligations, or privacy practices. When we do so, we will update the “Effective date” at the top. We encourage you to review this Privacy Policy periodically.
15. Contact Us
For questions about this Privacy Policy or our privacy practices, or to exercise your rights, please contact our Data Protection team:
Email: [email protected]
LIMINAL PRIME OTC (Additional Privacy Terms)
These additional terms apply to users of the Liminal Prime OTC service. They supplement the general privacy terms above; where there is no additional term on a topic, the general terms apply.
OTC.1 Additional data we collect
Identity and KYC/KYB data
To meet our legal and regulatory obligations we collect identity information about you and, where applicable, your organisation; including names, dates of birth, government-issued identification documents, proof of address, corporate documentation, and beneficial ownership information.
Compliance data
Information collected as part of our AML, CTF, and sanctions screening processes, including source of funds where required.
OTC.2 Additional purposes and legal bases
- KYC/KYB and onboarding (legal obligation): verifying your identity and your organisation’s identity before entering a trading relationship.
- AML, CTF, and sanctions compliance (legal obligation): screening against applicable sanctions lists, conducting due diligence, and filing required reports with competent authorities.
- Providing the OTC service (contract): executing trades, confirming settlements, and managing your account.
- Fraud prevention (legitimate interests): monitoring for suspicious activity.
OTC.3 Additional sharing
- Regulatory and law enforcement authorities, where required by applicable law.
- Financial crime intelligence networks or databases, as part of our AML/CTF obligations.
- Correspondent banks or settlement counterparties, where necessary to complete a transaction.
OTC.4 Retention
OTC transaction records, KYC/KYB documents, and compliance data are retained for at least five years from the end of the business relationship, or longer where required by applicable law.
LIMINAL PRIME BRIDGE (ADDITIONAL PRIVACY TERMS)
These additional terms apply to users of the Liminal Prime Bridge service. They supplement the general privacy terms above; where there is no additional term on a topic, the general terms apply.
Bridge.1 About the Bridge service
Liminal Prime Bridge is a technology service that facilitates price discovery and interaction between liquidity providers (Makers) and participants (Takers). Each participant is responsible for its own regulatory compliance obligations in connection with its activity on the service. We may collect business profile information, including organisation registration documents and identity details of affiliated individuals, solely to assess organisational legitimacy prior to granting access. We may restrict or suspend access where a participant fails to provide requested documentation or is found to be non-compliant with applicable law.
Bridge.2 Additional data we collect
In addition to the general data categories, for Bridge we collect:
- Login credentials and session tokens used to authenticate access to the platform.
- Order and quote data generated during your use of the platform, including order type, size, price, and execution status.
We carry out business-legitimacy and due-diligence checks on Bridge participants, as described in Bridge.1; we do not require full KYC/KYB documentation from Bridge participants in their capacity as market participants, except where a Sub-account pays fees to Liminal Prime directly or our admission due diligence otherwise requires it.
Bridge.3 Additional purposes and legal bases
Liminal Prime’s role in Bridge is limited to technology, order routing, matching, and communication. In the RFQ Model, Liminal Prime routes requests and quotes between Makers and Takers but does not itself match or execute the Trade Contract, which takes place on the selected Maker’s own venue. In the Firm Quote Model, orders are matched against the order book maintained on the Platform, and the resulting Trade Contract is formed on the Platform. In neither model does Liminal Prime provide clearing, settlement, or custody services; settlement always occurs bilaterally, off-platform, between Makers and Takers under their own agreements. Sanctions screening, AML, and other financial crime obligations sit with each Maker and Taker for their own activity. Liminal Prime processes personal data only to the extent necessary to provide the technology service itself.
- Providing access to the Bridge trading modes (contract) : authenticating users; in the RFQ Model, displaying quotes from Makers to Takers and routing RFQ requests and responses between participants; in the Firm Quote Model, maintaining the order book and matching orders to form Trade Contracts; and, in both models, capturing post-trade status and reconciliation data submitted by the parties.
- Operating and securing the service (legitimate interests) : maintaining service availability, preventing abuse, and investigating technical issues.
- Compliance with applicable law (legal obligation) : retaining service records to the extent required by applicable law and responding to lawful requests from competent authorities.
Bridge.4 Technology infrastructure and data handling
We use third-party technology infrastructure providers to operate the Bridge platform. These providers process personal data on our behalf under contractual obligations that include:
- Processing data solely for the purpose of providing the platform service.
- Minimising stored data,
- Segregating it from other customers’ data, and restricting access on a least-privilege basis.
- Retaining data only for as long as necessary; deleting or anonymising it on termination or on our written request.
- Providing us with a data export in a durable format on request.
These providers may be subject to their own legal obligations, including obligations to disclose data to competent authorities where required by law.
Bridge.5 Retention
Bridge.6 Additional sharing
- Technology infrastructure providers process platform data as described in Bridge.4.
- We do not share Bridge participant data with other Bridge participants beyond what is inherent in the operation of the trading platform (for example, counterparty identifiers visible in trade confirmations).