Privacy Policy
Privacy Policy
Effective from 05 March 2026
This Website Privacy Notice explains how Liminal Panama collects and uses personal data when you visit our website or contact us through our website. It is written to be clear and practical, while reflecting the requirements that may apply to international visitors, including the GDPR where relevant.
1. Who we are
First Answer Panama, Inc. acts as the controller for personal data processed in connection with this website.
- Controller: First Answer Panama, Inc.
- Address: World Trade Center, 200-B, Suite # (TBA) Calle 53 Este, Marbella Ciudad de Panama, PA, Republica de Panama
- Email (privacy contact): [email protected]
If we appoint an EU/UK representative or a Data Protection Officer for this website in the future, we will publish the relevant contact details here.
2. Scope of this notice
This Notice applies to personal data collected through:
- visits to our website (including technical and usage data), and
- enquiries submitted through our website (for example, via a contact form or email link).
This Notice does not describe how we handle personal data collected as part of a customer relationship, onboarding (KYC/KYB), AML/CFT processes, or services delivered under contract. Those activities are governed by separate contractual documents and/or dedicated privacy notices provided in the relevant context.
3. Personal data we collect
The personal data we collect depends on how you interact with the website.
Contact and enquiry data. If you submit an enquiry, we collect the information you provide, such as your name, organisation, email address, and the content of your message.
Technical and usage data. When you visit the website, our servers may automatically collect certain technical information, such as your IP address, browser type, device information, pages viewed, and timestamps. This information helps us operate and secure the website.
Cookie and analytics data. If you consent to analytics cookies via our cookie banner / preference centre, Google Analytics may collect information about your use of the website, which may include identifiers stored in cookies and information about your device and browsing behaviour.
3. Personal data we collect
We collect personal data in three main ways:
- Directly from you when you provide it to us (for example, when you submit an enquiry).
- Automatically through server logs and similar technical mechanisms when you browse the website.
- Through cookies and similar technologies where you consent to non-essential cookies (such as analytics cookies).
5. How we use personal data and legal bases
We use personal data only for purposes that are compatible with operating our website and responding to your requests.
Responding to enquiries. We use contact and enquiry data to respond to messages, provide information you request, and take steps at your request prior to entering into a business relationship. Where the GDPR applies, the legal basis is typically necessity to take steps prior to entering into a contract (Article 6(1)(b)) and/or our legitimate interests in communicating with prospective counterparties and business contacts (Article 6(1)(f)).
Operating and protecting the website. We use technical and usage data to operate, maintain, and secure the website, including preventing abuse and investigating technical issues. Where the GDPR applies, the legal basis is typically our legitimate interests in running and securing our website (Article 6(1)(f)), and compliance with legal obligations where applicable (Article 6(1)(c)).
Website analytics (Google Analytics). We use Google Analytics to understand how visitors use the website and to improve website performance and content. Where the GDPR and ePrivacy-style rules apply, we set analytics cookies only after you provide consent via our cookie banner / preference centre. The legal basis for analytics cookies is consent (Article 6(1)(a)). You can withdraw consent at any time.
6. Cookies, consent management, and Google Analytics
6.1 Cookies and similar technologies
Cookies are small text files that websites place on your device. We use cookies and similar technologies for two purposes:
- Strictly necessary cookies, which are required for the website to function properly and for basic security.
- Analytics cookies, which help us understand website usage and improve our site.
We do not use marketing or advertising cookies unless we specifically notify you and provide a choice through our cookie preference centre.
6.1 Cookies and similar technologies
When you first visit the website (and periodically thereafter), you will be presented with a cookie banner that allows you to accept or reject analytics cookies. You can change your preferences at any time by using the “Cookie settings” link on the website (or equivalent link provided by our consent management platform).
If you reject analytics cookies, we will not set analytics cookies and Google Analytics will not be used for your visit.
6.3 Google Analytics
Google Analytics helps us understand website usage patterns (such as which pages are visited and how users navigate the site). The information collected is used in aggregated form to improve website performance.
Google may process analytics data on our behalf as a service provider. For more information on how Google uses data, please refer to Google’s privacy information.
7. Sharing and disclosures
We share personal data only where necessary for the purposes described in this Notice.
Service providers. We use cloud and hosting providers and other IT service providers to operate the website and manage communications. These providers process personal data on our behalf under contractual obligations to protect it.
Analytics providers. If you consent to analytics cookies, Google Analytics processes certain website usage data as described above.
Legal and compliance disclosures. We may disclose personal data where required by law, regulation, legal process, or requests from competent authorities, or where necessary to protect our rights, users, or the integrity of the website.
Professional advisers. We may disclose personal data to professional advisers (such as lawyers, auditors, or consultants) where necessary for the purposes of advice, compliance, or dispute resolution.
8. International data transfers
Because we operate internationally and use service providers that may process data in different jurisdictions, personal data may be transferred and processed outside the country where you are located.
Where the GDPR applies and personal data is transferred outside the EEA/UK to a country that is not recognised as providing an adequate level of protection, we implement appropriate safeguards, such as the European Commission’s Standard Contractual Clauses (and UK equivalents where applicable), or other lawful transfer mechanisms.
9. Data retention
We retain personal data only for as long as necessary for the purposes described in this Notice.
- Enquiry data is retained for the period needed to respond and to maintain an appropriate record of communications, taking into account legal and compliance requirements.
- Technical logs are retained for security and operational purposes and are rotated in line with our security and operational needs.
- Analytics data retention depends on Google Analytics settings and is managed to support website improvement while respecting applicable requirements.
10. Security
We maintain reasonable technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure. No website can be guaranteed to be completely secure, but we take security seriously and continually review appropriate safeguards.
11. Your rights and choices
Depending on your location and applicable law (including the GDPR where relevant), you may have rights to:
- request access to personal data we hold about you;
- request correction of inaccurate or incomplete data;
- request deletion of your personal data;
- object to or request restriction of processing;
- request data portability in certain circumstances;
- withdraw consent where processing is based on consent (such as analytics cookies).
You may also have the right to lodge a complaint with a competent supervisory authority.
To exercise your rights, please contact us using the details in Section 15.
12. Children’s privacy
Our website is not directed to children and we do not knowingly collect personal data from children. If you believe a child has provided personal data to us, please contact us and we will take appropriate steps.
13. Third-party links
Our website may contain links to third-party websites. We are not responsible for the privacy practices of third parties and encourage you to review their privacy notices.
14. Changes to this notice
We may update this Notice from time to time. The “Effective date” at the top indicates when the Notice was last updated. If changes are material, we will take reasonable steps to notify visitors, such as by posting a prominent notice on the website.
15. Contact us
For questions about this Notice or our privacy practices, or to exercise your rights, please contact:
- Email: [email protected]
- Address: World Trade Center, 200-B, Suite # (TBA) Calle 53 Este, Marbella Ciudad de Panama, PA, Republica de Panama