Liminal Prime is Live! Built for exchanges, OTC desks, and cross-border stablecoin businesses.

Website Privacy Notice

Privacy Notice

Effective from 07 Sep 2026

1. Introduction

This Privacy Policy describes how Liminal Prime and its affiliates (“Liminal Prime“, “we“, “our” or “us”) collect, use, disclose, store and otherwise process your Personal Information in connection with: (i) your use of our website and its related websites and subdomains (the “Website”); (ii) your access to and use of our services (the “Services“); and (iii) other interactions with Liminal Prime where we act as the controller of your Personal Information under applicable data protection law.
“Personal Information” means information relating to an identified or identifiable individual. It does not include information that has been anonymised or aggregated such that it no longer identifies an individual, or publicly available information to the extent excluded under applicable law.
Liminal Prime operates through affiliated entities. Depending on the Service you use and the jurisdiction in which it is provided, one or more Liminal Prime affiliates may act as controller of your Personal Information, either independently or jointly. Contact details for privacy enquiries are set out in Section XV.

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 itWhat we collectWhy we collect it
When you visit our WebsiteCookies, analytics identifiers, IP address, browser type, device information, pages viewed, timestamps, navigation patternsOperate and secure the Website; analyze performance and usage; improve user experience
When you submit an enquiry or contact formName, organization, email address, phone number, assets of interest, estimated monthly volumes, and content of your messageRespond to your enquiry; take steps prior to entering a business relationship
When you subscribe to communicationsName, email address, organization nameSend you product news, updates and marketing communications, where permitted
When you interact with us at events or on social mediaName, business contact details, public profile information, content of interactionsFollow up on your interest; maintain business relationships

Onboarding and compliance

When we collect itWhat we collectWhy we collect it
When onboarding is requiredIdentity 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 developmentName, business contact details, job title, employer, professional profile information; information from publicly available sources or trusted third-party data providersDevelop and maintain business relationships; identify organizations that may be interested in our Services

Account and service use

When we collect itWhat we collectWhy we collect it
When you create an accountName, business email address, contact details, role or job titleCreate and manage your account; authenticate access; send service communications
When you access or use the ServicesAccount and user profile data; API request metadata and logs, including IP addresses; audit and activity logs; session tokens and authentication dataProvide, operate, secure and audit the Services; authenticate access; investigate incidents
When you use our ServicesWallet addresses, bank account details, settlement instructions, and related service records generated through your use of the ServicesEnable and support the delivery of the Services; retain records as required by law
When you or your organization are billedBilling contact name and email, payment method details processed by our payment processorsProcess 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:

Where required by applicable law, we rely on one or more of the following legal bases:

4. How We Share Personal Information

We share Personal Information only where necessary. We may disclose Personal Information to:

  1. 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.
  2. 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.
  3. 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.
  4. Analytics providers
    Where you consent to analytics cookies, certain website usage data is processed by analytics service providers on our behalf.
  5. Payment processors
    Payment method details are processed by our payment processors. We do not store full payment card details.
  6. Professional advisers
    We may share Personal Information with lawyers, auditors, insurers, and consultants where necessary for advice, compliance, or dispute resolution.
  7. 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.
  8. 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:

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

You may opt out of marketing communications at any time using the unsubscribe link in our communications or by contacting us at [email protected]. We may still send you service-related or administrative communications that are not promotional in nature.

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

OTC.3 Additional sharing

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:

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.

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:

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 transaction and account data is retained for as long as necessary for the purposes described above, or as required by applicable law. Data held by our infrastructure providers on our behalf is subject to equivalent retention controls, including deletion or anonymisation on termination of the relevant arrangement.

Bridge.6 Additional sharing