- About Ripple Liquidity Hub Services
- Ripple as a Service Provider
- Information We Collect
- How We Use Information
- How We Share Information
- How We Transfer, Store, Protect, and Retain Information
- Third-Party Services, Applications, and Websites
- Privacy Choices and Rights
- Minimum Age Requirements to Use Liquidity Hub Services
- Contacting Us
- Liquidity Hub California Consumer Privacy Act (“CCPA”) Addendum
- Liquidity Hub General Data Protection Regulation (“GDPR”) Addendum
Effective Date: April 15, 2022
About Ripple Liquidity Hub Services
Ripple as a Service Provider
Information We Collect
The information we collect depends on the context of our Customers’ interactions with Liquidity Hub Services and the choices they make (including the privacy settings), the features used, their location, and applicable law. In some cases, we receive information directly from Customers, such as name and email address when creating an account. In other cases, we receive information through our Customers’ use of the Liquidity Hub Services, such as business contact and transaction details and information collected through automated means, such as user IDs.
Information You Provide Directly to Us
We collect the following information when Customers use the Liquidity Hub Services.
- Due diligence information - To provide the Liquidity Hub Services, we use a third party to conduct “Know Your Customer” (“KYC”) diligence on our Customers’ End Users to ensure that Ripple complies with applicable laws and regulations, including anti-money laundering requirements. Our KYC service provider collects Customer business information (e.g., company name and title).
- Contact information - We collect contact information when Customers use the Liquidity Hub Services. For example, when a Customer creates a Liquidity Hub account, we collect the business account holder’s full name, address, telephone number, and email address.
- Identity information - We collect information about the identity of Customers’ beneficial owners, including name, nationality, country of residence, and date of birth on behalf of the Customer.
- Account information - We collect information about a Customer’s account, such as username, user ID, password, and date of account creation.
- Communication information - When Customers engage with us, we collect information provided by the Customer, including through form submissions, email communications, or phone calls to inquire about Ripple and the Liquidity Hub Services.
- Troubleshooting and support information - We collect information about a Customer’s account preferences or data provided when Customers contact Ripple for support (e.g., the solution used, contact or authentication data, the content of chats and other communications with Ripple, and other details that help us provide Customer support).
- Any information you voluntarily provide to us, such as when Customers submit an inquiry through our support portal (e.g., contents of a message or attachments that Customers send to us).
Information We Collect Automatically
When Customers use or interact with the Liquidity Hub Services, we automatically collect or receive certain information about devices and usage of the Liquidity Hub Services. This information includes:
- Usage information - We collect information about our Customers’ usage of the Liquidity Hub Services. This information includes browser type and settings, usage details (e.g., timestamps), language preferences, device event information (e.g., system activity and hardware settings, application version, and amount of time spent on the Liquidity Hub Services), and information about how Customers interact with the Liquidity Hub Services (e.g., loading errors and date/time stamps associated with Customer usage).
- Device information - We collect information about devices automatically when using the Liquidity Hub Services. This information includes web browser and device characteristics, operating system, IP address, location, device type, Internet service provider, mobile network, system configuration information, model, model number, push notification tokens, and unique device identifiers (e.g., username and password).
- Anonymized Statistical information - We collect additional anonymized statistical or other aggregated, de-identified information about how Customers use the Liquidity Hub Services (e.g., transaction ID, user ID).
Some information collected within the Liquidity Hub Services, whether alone or together with other data, may personally identify individuals. Depending on the Liquidity Hub Services provided, we collect this information on behalf of our Customers and/or requested by the Customer and under the direction of our Customers, such as transaction and account history. In such instances, if you are an End User and would like to understand what information our Customers collect, please contact the entity that you interact with directly.
How We Use Information
Ripple uses collected information in the following ways:
- Communicate with Customers about the Liquidity Hub Services - We use personal information to communicate with Customers about their access to and usage of the Liquidity Hub Services, which includes sending technical notices, updates, security alerts, and support and administrative messages (e.g., notification of changes to our terms and conditions and notices, invitations to join the service, or requests to contribute to a trust).
- Provide the Liquidity Hub Services - We use Customer and Customer End Users’ information to provide, operate, monitor, and maintain the Liquidity Hub Services.
- Provide and improve necessary functionality - We use Customers’ information to provide the necessary functionality required during use of the Liquidity Hub Services. We also analyze how Customers use our products and services to deliver the Liquidity Hub Services, and improve functionality, quality, and user experience.
- Transactional considerations - If Customers choose to conduct financial transactions using Liquidity Hub Services, we use their information to complete transactions, and send them related information (e.g., purchase confirmations, receipts, invoices, and verification and authorization confirmations).
- Handle contact and support requests - If Customers contact us for support, we use their information to fulfill their requests and communicate with them. We also process personal information to respond to Customer comments, questions, and requests, and provide customer service and support via email, chat, or phone.
- Develop and improve our products and services - We use personal information to review and analyze trends, usage, and interactions with the Liquidity Hub Services and to personalize and improve our services. We also use Customer information to provide content and/or features that match Customers’ interests and preferences and their experience with the Liquidity Hub Services.
- Promote the security of our products and services - We use Customer and their End Users’ information to investigate and prevent fraudulent transactions, unauthorized access to the Liquidity Hub Services, and other malicious, deceptive, fraudulent, or illegal activity.
- Legal, regulatory, safety and compliance purposes - We use Customer and their End Users’ information to comply with applicable laws or regulations and to review compliance with Ripple usage terms, as well as audits, security, and fraud monitoring and prevention. For example, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.
- Other purposes - We use Customers’ information for other purposes about which we notify Customers in advance, or for which we provide notice of or receive their consent (such as in the event of a sale, merger, or acquisition).
How We Transfer, Store, Protect, and Retain Information
Third-Party Services, Applications, and Websites
Privacy Choices and Rights
Individuals have certain choices and rights when it comes to how we collect and use their personal information. Below is a summary of those choices and rights, and how to exercise them.
- Account deletion: If a Customer discontinues using the Liquidity Hub Services, we can delete certain information upon request. Please note some latency in deleting this information from our servers and back-up storage may occur if necessary to comply with our legal obligations, resolve disputes, manage security risks, or enforce our agreements.
Depending on where a Customer or their End User is located, certain rights are available in connection with personal information that we obtain. These rights vary depending on jurisdiction. To learn more about these rights, see the:
- Liquidity Hub CCPA Addendum if the individual is a California resident.
- Liquidity Hub GDPR Addendum if the individual is located in the EEA or United Kingdom.
Minimum Age Requirements to Use Liquidity Hub Services
Attention: General Counsel
315 Montgomery Street, 2nd Floor
San Francisco, CA 94104
Liquidity Hub California Consumer Privacy Act (“CCPA”) Addendum
Additional provisions applicable to processing personal information of California residents.
Scope and Applicability
Data Collection, Use and Sharing
The CCPA requires that we inform individuals whether we collect any categories of personal information as classified under the CCPA, and whether we share this information with selected recipients for specific purposes.
Categories of Information
We collect the following categories of information as classified under CCPA:
- Personal identifiers - We collect name, phone number, email address, billing addresses, login credentials, and IP address.
- Personal information - We collect date of birth.
- Characteristics of protected classifications - We collect date of birth and gender, but do not use this information to infer whether an individual belongs to a protected age group.
- Commercial information - We collect information about the products requested and records of services purchased.
- Internet or other network activity information - We collect network, account, and transaction activity history, information collected from cookies and similar technologies, and analytics data.
- Other inferences drawn from personal information - We draw inferences from the categories of information collected to understand a consumer’s preferences, characteristics, or predispositions.
We collect and use personal information to:
- Interact with Customers
- Facilitate transactions
- Provide the Liquidity Hub Services
- Conduct internal research and development
- Improve the quality and safety of our products and services
- Detect security incidents and prevent fraud.
Your CCPA Rights
Attention: General Counsel
315 Montgomery Street, 2nd Floor
San Francisco, CA 94104
Liquidity Hub General Data Protection Regulation (“GDPR”) Addendum
Additional provisions applicable to the processing personal information of individuals based in the European Economic Area (“EEA”) and the United Kingdom (“UK”).
Scope and Applicability
Data Collection, Use and Sharing
Ripple acts as a data processor on behalf of our Customers for most of the personal information we process through the Liquidity Hub Services. Our Customers primarily control what personal information we collect and process through the Services and how we use it, and we only process information in accordance with their instructions.
This GDPR Addendum does not apply to any personal information that we process as a processor, as we only process that information on behalf of the Customer and in accordance with our Agreement with them. A Customer that has entered into an agreement to use the Liquidity Hub Services controls its instance of the Services and any associated data.
We collect and process personal information only where we have a legal basis for doing so under applicable data protection laws. Our legal bases include processing personal information under:
- Customer consent: Where appropriate or legally required, we collect and use personal information subject to our Customers’ consent. For example, we collect email address when signing up for emails and updates on the Liquidity Hub Services.
- Performance of contract: We collect and use information to contract with Customers or to perform a contract that Customers have with us. For example, we collect name, email, and billing addresses when Customers’ purchase the Liquidity Hub Services and process transactions.
- Legitimate interests: We collect and use information for our legitimate interests to improve the Liquidity Hub Services, deliver content, optimize Customers’ experience, and market the Liquidity Hub Services. For example, we collect Customers’ IP address and device information when they use the Liquidity Hub Services to prevent malicious activity and fraudulent transactions.
- Compliance with laws: We may also collect and use information:
- As required by law, such as to comply with a subpoena or similar legal process;
- When we believe in good faith that disclosure is necessary to protect our rights or property, protect one’s health and safety or the health and safety of others, investigate fraud, or respond to a government request; or
- If we participate in a merger, acquisition, or sale of all or a portion of its assets.
Transfer of Personal Information to Other Countries
Data Subject Rights
If you are an End User of the Liquidity Hub Services seeking to access, correct, amend, or delete personal information, please contact the Customer (the data controller) that has transferred such data to us for processing. If the Customer receives a data subject request and sends the request to us, we will respond to the Customer’s request within the agreed timeframe outlined in our Customer agreement. The Customer is responsible for responding to its End User data subject requests as determined under the applicable local data protection law.