Section 1 – Information We Collect

We may collect and process the following categories of personal information when you use Livit.

1.1 Account Information

When you create an account, we may collect:

• Name

• Email address

• Phone number

• Password or authentication credentials

• Account verification details

• Date of birth, if you choose to add it to your account (for example, to receive birthday offers)

1.2 Profile Information

Information you provide on your Livit profile, including:

• Profile photo

• Location

• Username

• Preferences or account settings

1.3 Identity Verification Information

To maintain trust and safety on the Platform, Livit may collect identity verification information, including:

• Government-issued identification details

• UAE Pass authentication data, verified through the UAE Pass digital identity platform. Where available through this verification, this may include your date of birth.

• Selfie or biometric verification data, verified through our identity verification provider

Some of this information, including biometric and government ID data, is treated as sensitive personal data under the UAE PDPL. We only collect and process this information with your explicit consent, and it is used solely for identity verification and fraud prevention. See Section 7 (Sensitive Personal Data) for more detail.

1.4 Transaction Information

When you buy or sell items through Livit, we collect information relating to the transaction, including:

• Items purchased or sold

• Transaction value

• Payment method

• Delivery details

• Order history

• Dispute or refund information

Payments are processed by our payment processing partner. Livit does not store your full card details.

1.5 Reviews and Ratings

After a transaction is completed, buyers and sellers may leave reviews and star ratings about each other. Reviews and ratings you give or receive, including any written feedback, may be visible to other Users on the Platform. See Section 5.1 (Other Users) for more detail on what's shared.

1.6 Payout and Withdrawal Information

If you sell on Livit, funds from your sales are held in your Livit wallet. When you request a withdrawal, you provide your IBAN and account holder name directly to Livit. Our team manually reviews withdrawal requests before processing payouts, and this information is accessible only to a limited number of authorised team members.

1.7 Communication Data

We may collect information when you:

• Contact customer support

• Communicate with other users through the Platform

• Submit feedback or reports

This may include messages, attachments, and support communications.

To help keep the Platform safe, messages sent between users may be automatically scanned and, where necessary, manually reviewed by our team to detect fraud, scams, prohibited items, harassment, or other violations of our Terms and Conditions. See Section 2.3 (Safety and Trust) for more detail.

1.8 Device and Technical Data

When you use the Platform, we may automatically collect technical information such as:

• IP address

• Device type and operating system

• App version

• Device identifiers

• Usage and interaction data, including through analytics tools

• Log data and diagnostics

1.9 Location Information

We collect location information for two purposes:

• Delivery: delivery addresses, location data associated with delivery, and delivery confirmation data (timestamps, GPS confirmation, or proof of delivery)

• Listings and browsing: with your permission, we may collect your device's precise location to set the location shown on your listings and to let buyers browse or search for items near them

1.10 Listing Photos and AI-Generated Suggestions

When you create a listing, you may upload photos of the item. These photos are processed using AI to automatically suggest a brand, category and description for your listing. You can review, edit, or reject these suggestions before publishing. See Section 4 (Artificial Intelligence and Automated Decisions) for more detail on how this data is used.

Section 2 – How We Use Your Information

We use personal information for the following purposes:

2.1 Providing the Platform

To operate and maintain the Livit Platform, including:

• Creating and managing user accounts

• Facilitating buying and selling transactions

• Processing payments and payouts

• Managing deliveries through approved logistics partners

• Enabling reviews and ratings between Users

• Operating the Livit Ensure buyer protection service

2.2 Communication

To communicate with users, including:

• Transaction updates

• Customer support responses

• Service notifications

• Security alerts

2.3 Safety and Trust

To maintain a safe marketplace environment, including:

• Fraud prevention

• Identity verification

• Monitoring suspicious activity, including automated and manual review of messages exchanged between users to detect fraud, scams, prohibited items, harassment, or other violations of our Terms and Conditions

• Resolving disputes between users

2.4 Platform Improvement

To analyse platform performance and user behaviour in order to:

• Improve features

• Enhance the user experience

• Optimise platform security and reliability

2.5 Marketing and Promotional Content

Where you have opted in at sign-up or at another point of collection, we may send you promotional messages, product updates, and offers directly, for example by email or push notification. Where you have added your date of birth to your account, we may also use it to send you birthday-related offers as part of these messages. You may withdraw this consent and opt out at any time.

We also publish general product updates and other content on our blog at thelivit.app. This content is published for anyone to read and is not sent to you individually, so it does not rely on your consent.

2.6 Legal Compliance

To comply with applicable laws, regulations, and legal obligations.

Section 3 – Grounds for Processing Your Data

We only process your personal data where we have a valid basis to do so under the PDPL. Depending on the activity, this may be:

• Consent: for example, biometric verification, marketing messages, and precise location collection

• Performance of a contract: for example, processing transactions, facilitating deliveries, and providing customer support

• Legal obligation: for example, complying with UAE laws, regulatory requests, and record-keeping requirements

• Legitimate interest: for example, fraud prevention, platform security, and improving our services, weighed against your rights and interests

Section 4 – Artificial Intelligence and Automated Decisions

We use artificial intelligence (“AI”) and other automated tools to operate and improve the Platform. This includes analysing photos you upload to suggest a listing's brand, category, condition, and description, and helping us detect fraud, prohibited items, and other violations of our Terms and Conditions.

What this means for your data:

• Listing photos and related data you submit are processed by trusted AI providers acting on our behalf and under contract, currently OpenAI. This is a standard part of creating a listing on Livit, so it isn't something you can turn off individually, though you can always review, edit, or reject the AI's suggestions before publishing.

• We rely on the performance of our contract with you (to provide listing tools) and our legitimate interests (to keep the Platform safe and to improve our services) as the basis for this processing, not on your separate consent.

• Separately, OpenAI does not use data sent through its API to train its own models by default. This is a setting on Livit's OpenAI account rather than something you need to do, and OpenAI may still retain data for a short period, currently up to 30 days, to monitor for misuse of its services.

• Where automated processing could significantly affect you, for example a decision to suspend your account, we keep a human involved in the decision, and you can contact us to request a review.

• Because OpenAI may process data outside the UAE, this may involve an international transfer of your data, which we carry out in line with Section 11 (Data Transfers Outside the UAE).

Section 5 – Disclosure of Your Information

We may share your personal information in the following circumstances.

5.1 Other Users

When a transaction occurs, certain information may be shared with other users involved in the transaction, including:

• Username

• Item details

• Delivery information necessary to complete the transaction

• Any reviews or ratings you give or receive

5.2 Service Providers

We share information with trusted third-party service providers who help us operate the Platform. These currently include:

• Payment processing. Buyer payments are processed through a third-party payment processor. Seller payouts are handled directly by us following manual review, and are not currently processed through the same payment provider.

• Cloud hosting and data storage

• Identity verification

• Product and app analytics

• AI-assisted listing suggestions

• Delivery and logistics

• Automated customer communications, which sends event-triggered messages to customers, for example order and account updates, based on data in our systems

• Customer support platforms

These providers are contractually required to process data only for authorised purposes and in line with this Privacy Policy. We periodically review this list and will update it as our vendors change.

5.3 Legal Requirements

We may disclose information if required to do so:

• By law

• By a court order

• By a regulatory authority

• To protect the rights, property, or safety of Livit, its users, or the public

5.4 Business Transfers

If Livit undergoes a merger, acquisition, restructuring, or sale of assets, personal information may be transferred as part of that transaction. If this happens, we'll let you know and take reasonable steps to make sure your data continues to be protected under this Policy.

Section 6 – Your Rights

Subject to applicable law, you may have the following rights regarding your personal data:

• Access: request access to the personal data we hold about you

• Correction: request correction of inaccurate or incomplete information

• Deletion: request deletion of your personal data where permitted by law

• Withdrawal of Consent: withdraw consent for certain types of processing, including biometric verification and marketing

• Objection: object to processing for direct marketing purposes

• Automated Decisions: request human review of an automated decision that has a significant effect on you

• Complaint: lodge a complaint with the UAE Data Office if you believe your data has been processed unlawfully

You can manage many account details, such as your profile information and notification preferences, directly within the Livit app. For anything else, contact us using the details below, and we will respond within the timeframe required by law.

support@thelivit.app

Section 7 – Sensitive Personal Data

Some of the information we collect, including biometric verification data and government-issued identification details, is classified as sensitive personal data under the PDPL. We only collect and process this information:

• With your explicit consent

• For the specific purpose of identity verification and fraud prevention

• With restricted internal access, limited to personnel who need it to perform verification

• For no longer than necessary to complete verification and meet our legal record-keeping obligations, after which it is deleted or anonymised

You may withdraw consent for this processing at any time, though this may limit your ability to use certain features of the Platform, such as buying or selling, that require identity verification.

Section 8 – Data Security

We take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, misuse, alteration, and disclosure.

Passwords are never stored in a readable form; they are protected using industry-standard one-way hashing methods, meaning your actual password is never accessible to us, including our own staff.

Where we collect government-issued identification numbers as part of our identity verification process, we do not store the number itself. Instead, we retain a secured, non-reversible reference sufficient to prevent duplicate registrations, along with a partially masked version for display purposes only.

Identity documents and verification photos submitted as part of our verification process are stored separately from other content on our platform, in a restricted-access location that is not publicly accessible and cannot be reached via a direct link.

We do not collect or store your full payment card details. Card payments are processed directly by our payment processing partner through their own secure systems; we retain only a tokenised reference sufficient to facilitate future transactions, not your card number or security code.

Data transmitted between your device and our servers is protected using encryption in transit.

We maintain safeguards designed to prevent unauthorised changes to your personal data.

Access to personal data within our organisation is restricted to authorised personnel on a need-to-know basis and is governed by internal access controls.

We work with a limited number of trusted service providers to operate our platform, including for payment processing, cloud hosting and data storage, identity verification, push notifications, and product analytics. These providers are contractually bound to protect your data and may only use it to provide services to us.

However, no method of internet transmission or electronic storage is completely secure, and absolute security cannot be guaranteed.

Section 9 – Data Retention

We retain personal information for as long as necessary to:

• Provide the Platform and its services

• Comply with legal obligations

• Resolve disputes

• Enforce our Terms and Conditions

As a minimum, we retain personal data for the period required under applicable UAE law. Retention periods may otherwise vary depending on the type of information and the purpose for which it was collected.

Section 10 – Cookies and Tracking Technologies

Livit may use cookies and similar technologies, which generally fall into the following categories:

• Essential: needed for the Platform to function, for example login and security

• Analytics and performance: help us understand how Users interact with Livit

• Functionality: remember your preferences, such as language and recently viewed items

• Marketing: help us measure the performance of our campaigns, where applicable

Further details are provided on request.

Section 11 – Data Transfers Outside the UAE

Some of our service providers process data outside the United Arab Emirates. This currently includes:

• Cloud hosting and data storage providers

• Other service providers, which may process data in the United States, the European Union, or other jurisdictions where they operate

Where such transfers occur to jurisdictions that do not have a UAE Data Office adequacy decision, we put appropriate safeguards in place, such as Standard Contractual Clauses or equivalent contractual protections, to protect your personal data in accordance with the PDPL.

Section 12 – Links to Other Websites and Services

The Platform may include links to websites, apps, or services that we don't operate. This Privacy Policy doesn't cover how those third parties handle your information, so we'd encourage you to check their own privacy policies before sharing anything with them.

Section 13 – Children’s Data

The Livit Platform is intended for users aged 18 and over.

We do not knowingly collect personal data from individuals under the age of 18. If we become aware that personal information has been collected from a minor, we will take reasonable steps to delete the information.

Section 14 – Compliance with UAE Data Protection Law

Livit processes personal data in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and applicable regulatory requirements.

Section 15 – Data Protection Officer

Livit is responsible for overseeing our compliance with the PDPL. You can contact us with any questions about this Privacy Policy or how we handle your personal data at:

support@thelivit.app

Section 16 – Changes to This Privacy Policy

We may update this Privacy Policy periodically.

If material changes are made, we will notify users through the Platform or by other appropriate means.

The updated policy will be effective once published.

Section 17 – Contact Us

If you have questions about this Privacy Policy or our data practices, please contact:

Livit Digital FZCO

IFZA Business Park

Premises 70698 001

DDP A1

Dubai Silicon Oasis

PO BOX 342001

United Arab Emirates

Email: support@thelivit.app