Liquifi LLC Privacy Policy

1. Who We Are

Liquifi LLC (“Liquifi,” “we,” “us,” or “our”) is a broker-dealer registered with the U.S. Securities and Exchange Commission (“SEC”) and a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). Liquifi operates the Liquifi Platform at www.liquifi.com for private-placement brokerage and secondary-market activities.

2. Scope and Relationship to Other Policies

This Privacy Policy applies to non-public personal information (“NPI”) we collect from:

  • Visitors to, or users of, the Liquifi Platform;

  • Individuals who obtain financial products or services from us (“customers”); and

  • Prospective customers and other consumers as defined in Regulation S-P.

It does not replace:

  • Venture360’s privacy documents that govern the separate Venture360 Platform; or

  • Any privacy statement delivered by the issuer of securities you purchase through Liquifi.

3. Information We Collect

Category

Examples

Source(s)

Identification

Name, address, e-mail, telephone, date of birth, government ID, SSN/Tax ID

Directly from you; KYC service providers

Financial

Bank and brokerage account numbers, wire instructions, income, net worth, investment objectives

Account applications; thirdparty verification databases

Transaction

Positions, funding events, bids, asks, settlement instructions, trade confirmations

Liquifi trade systems; clearing agents

Behavioral & Device

Cookies, IP address, device identifiers, click-stream data

Your browser/device; analytics partners

You may decline to provide data, but certain products or services may not be available.

4. How We Use Information

  • Brokerage & transactional services—to open, maintain and service accounts; clear and settle trades; issue confirmations; generate tax forms.

  • Regulatory compliance—customer identification (CIP/KYC), AML screening, sanctions screening, and other obligations under SEC, FINRA, and Bank Secrecy Act rules.

  • Risk management and fraud prevention: to protect customers and the firm from unauthorized transactions or identity theft (Regulation S-ID).

  • Marketing—to offer Liquifi or affiliate products and services, subject to the opt-out rights described in Section 7.

  • Business operations—audit, accounting, legal, and information-security functions, testing, and improving the Liquifi Platform.

5. How We Share Information

Reason for sharing

Do we share?

Can you limit?

Every day business purposes (processing, maintaining accounts, legal or regulatory reporting)

Yes

No

Marketing to you by Liquifi or wholly-owned affiliates

Yes

No

Joint marketing with other financial companies

No

Not applicable

Affiliate marketing (information about your creditworthiness)

No (Liquifi doesn’t collect credit scores)

Not applicable

Non-affiliate marketing

No, unless you consent

Yes (default is no sharing)

Service providers (IT, cloud hosting, auditors, clearing and settlement agents)

Yes—under confidentiality agreements

No

As required by law or government authorities

Yes

No

6. Safeguarding & Data Security

Liquifi maintains written policies and procedures reasonably designed to:

  • Protect the confidentiality and security of customer records and information as required by Regulation S-P Rule 30;

  • Detect, respond to, and recover from cyber-incidents in line with FINRA Regulatory Notice 22-29 guidance; and

  • Ensure business continuity under FINRA Rule 4370. Security controls include encryption in transit and at rest, multi-factor authentication for privileged access, vendor due-diligence, periodic penetration testing, and employee training.

7. Your Privacy Choices

  • Opt-Out of Non-Affiliate Sharing: Regulation S-P allows customers to opt out of Liquifi sharing NPI with non-affiliated third parties for marketing purposes. No action is necessary because Liquifi does not share NPI with non-affiliates for marketing purposes.

  • Affiliate Marketing Opt-Out: Liquifi currently does not use eligibility information for affiliate marketing. If that changes, you will receive a separate notice and opt-out form.

  • Do-Not-Track / Cookies: Browser settings may limit or disable cookies, which may impair some site functionality.

8. International, State & Special-Category Notices

  • California Consumers: We do not sell personal information. California residents can request access to or deletion of personal information subject to statutory exemptions (e.g., GLBA-regulated data).

  • EU / UK / EEA Individuals: Where Liquifi interacts directly with EEA/UK persons, Liquifi relies on contractual necessity (Article 6(1)(b), GDPR) or legitimate interests for processing and transfers subject to standard contractual clauses.

  • Children: Liquifi’s services are directed to individuals 18 and older. We do not knowingly collect children’s data.

9. Delivery of Privacy Notices

We provide this Privacy Policy to customers at the time of account opening and annually thereafter, as required by SEC Regulation S-P. We may also provide additional privacy notices or updates as needed to reflect changes in our practices or legal requirements.

10. Access & Correction

Customers may review and update certain account information by logging into the Liquifi Platform or by contacting us at support@liquifi.com.

11. Changes to This Policy

We will provide advance notice of material changes as required by Regulation S-P and FINRA Rule 2210, and post the revised policy on the Liquifi Platform.

12. Contact Us

Privacy questions or opt-out requests:

E-mail: support@liquifi.com