Privacy Policy

Effective Date:  05/09/2025

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Introduction
LivLive ("we," "our," or "us") operates a real-world gaming platform that transforms everyday movement and location-based activities into digital value through our website, mobile application, and connected wristband devices. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our services.

By accessing or using LivLive services, including our website at join.livlive.com, mobile application, and wristband devices, you agree to the collection and use of information in accordance with this Privacy Policy.

Company Information
LivLive services are provided by:

LivLive Inc.
55th street East, P.H. SL55 Building, Floor 21, Suite 3, Panama City, Republic of Panama
Responsible for $LIVE token issuance and crypto-related activities

Contact Information:
Email: hello@livlive.com

1. Personal Data We Collect
We collect various types of personal information to provide and improve our location-based gaming services, facilitate social interactions, and deliver personalized experiences through our platform.

Account and Profile Information
When you create a LivLive account, we collect basic identification information including your full name, email address, phone number, and date of birth to verify you meet our minimum age requirement of 18 years. We also collect profile information you choose to provide, such as profile pictures, usernames, and biographical information that helps personalize your gaming experience and enables social connections with other users.

Location and Movement Data
As a location-based gaming platform, we collect precise geolocation data through your mobile device's GPS, Wi-Fi, Bluetooth, and cellular signals. This includes your real-time location coordinates, movement patterns, speed of travel, and altitude information. We track your check-ins at specific venues, businesses, and points of interest, along with the duration of your visits and frequency of returns to particular locations.

Wristband and Sensor Data
Our connected wristbands collect biometric and activity data including heart rate, steps taken, calories burned, sleep patterns, and other wellness metrics. The wristband also captures movement acceleration, gyroscopic data, and proximity information when interacting with other LivLive users or scanning location-based rewards and challenges.

Camera and Augmented Reality Data
When you use our AR features, we process camera input from your mobile device to overlay digital content onto your real-world environment. This includes analyzing visual elements in your surroundings to place virtual objects, detect other users, and verify your presence at specific locations for quest completion and reward claiming.

Social and Communication Data
We collect information about your social interactions within the platform, including friend connections, messages sent and received, group memberships, team challenges participated in, and social media account information if you choose to link external accounts. We also track your engagement with other users' content, reviews, and recommendations.

Business and Review Data
When you check in at businesses, leave reviews, or rate services, we collect detailed information about your experiences, including written reviews, star ratings, photos you upload, and metadata about the timing and context of your visits. We also track your preferences and behaviors related to different types of businesses and services.

Device and Technical Information
We automatically collect technical information about your devices, including device identifiers, IP addresses, browser types and versions, operating system information, mobile carrier details, and device settings. We also collect usage analytics such as app session duration, feature usage patterns, and performance metrics.

Payment and Transaction Data
For users participating in our token presale or making purchases, we collect payment information including billing addresses, payment method details (processed securely through third-party payment processors), and transaction history related to $LIVE token purchases and wristband orders.

Communication and Support Data
When you contact our customer support team, we collect the content of your communications, including emails, chat messages, and any attachments or screenshots you provide to help resolve issues or answer questions about our services.

2. How We Collect Personal Data
We employ multiple collection methods to gather the personal information necessary for our location-based gaming platform to function effectively and provide personalized experiences.

Direct Collection from Users
We collect information directly from you when you voluntarily provide it through various interactions with our platform. This occurs when you create an account by filling out registration forms on our website or mobile application, where you provide basic contact and profile information. You also directly provide information when you customize your profile settings, update your preferences, or modify your account details through our user interface.

During the onboarding process for new wristband users, you provide additional information through setup forms and initial configuration steps that help calibrate your device and establish baseline activity metrics. When you participate in our community features, you directly share information by posting reviews of businesses, uploading photos, writing comments, and engaging in social interactions with other users.

Automatic Collection Through Technology
Our platform automatically collects significant amounts of data through various technological means integrated into our services. Your mobile device continuously transmits location data through GPS, cellular triangulation, Wi-Fi positioning, and Bluetooth beacons, which we use to track your real-world movements and enable location-based features.

The LivLive wristband automatically collects biometric and activity data through embedded sensors that monitor your physical activity, heart rate, sleep patterns, and other wellness metrics throughout the day. This data is transmitted to our servers through Bluetooth connectivity with your paired mobile device.

Our mobile application automatically collects device information, usage analytics, and performance metrics whenever you interact with the app. This includes tracking which features you use, how long you spend in different sections of the app, and technical performance data that helps us optimize the user experience.

Camera and Environmental Scanning
When you use our augmented reality features, we collect visual data through your device's camera to analyze your environment and overlay digital content. This environmental scanning helps us verify your location, detect nearby objects and landmarks, and enable interactive AR experiences that are central to our gaming platform.

The camera also captures images when you take photos for reviews, document quest completions, or participate in location-based challenges that require visual verification of your presence at specific venues or landmarks.

Third-Party Integrations and APIs
We collect information through integrations with third-party services and APIs that enhance our platform's functionality. This includes data from mapping services that provide detailed location information, weather APIs that influence gameplay elements, and social media platforms if you choose to connect your external accounts.

Payment processors provide us with transaction data when you make purchases, though sensitive financial information is handled directly by these secure third-party services rather than being stored on our systems.

Business Partner Data Sharing
Local businesses and venue partners may share information with us about your visits, purchases, or interactions when you use LivLive features at their locations. This partnership data helps us verify quest completions, process rewards, and provide businesses with valuable insights about customer engagement patterns.

Cookies and Tracking Technologies
Our website and mobile application use cookies, web beacons, and similar tracking technologies to collect information about your browsing behavior, preferences, and interactions with our digital properties. These technologies help us maintain your session state, remember your preferences, and analyze usage patterns to improve our services.

We also use analytics tools and tracking pixels to understand how users navigate our platform, which features are most popular, and where users may encounter difficulties or drop-off points in their journey through our application.

International Data Representative (GDPR Art. 27) –

Because LivLive’s primary entities are established outside the EEA/UK but offer services to individuals there, we have appointed VeraSafe Ireland Ltd., Suite 185, 3rd Floor, The Masonry, 151 Thomas St, Dublin 8, Ireland as our EU/UK representative. EU/UK residents may contact VeraSafe on matters relating to our EU/UK data processing.

2.1 Legal Bases for Processing (EEA / UK)
We rely on the following GDPR/UK-GDPR bases:

Contract (Art. 6 (1)(b)) – to create and maintain your LivLive account, issue rewards, and deliver purchased goods.

Legitimate interests (Art. 6 (1)(f)) – to detect fraud, secure our platform, and generate aggregated business insights.

Consent (Art. 6 (1)(a)) – for precise GPS tracking when the app is in the background, marketing e-mails, and linking social-media accounts. You can withdraw consent at any time in Settings › Privacy.

Legal obligation (Art. 6 (1)(c)) – for tax, bookkeeping, and compliance with financial-crime regulations.

3. Why We Collect and Use Personal Data
We collect and process your personal information for specific, legitimate business purposes that enable us to provide our location-based gaming services, generate revenue through our business model, and continuously improve the user experience.

Core Service Provision
The primary purpose for collecting your personal data is to deliver the fundamental features of our location-based gaming platform. Your location data enables us to create personalized quests and challenges based on your geographic area, allowing you to discover new places and participate in location-specific activities. We use your movement and activity data from the wristband to track quest progress, calculate rewards, and provide real-time feedback on your gaming achievements.

Your profile and social data facilitate community features that are essential to the LivLive experience, including friend connections, team challenges, leaderboards, and social sharing of accomplishments. We process your check-in and review data to verify quest completions, award experience points and tokens, and maintain the integrity of our reward system.

Personalization and User Experience Enhancement
We analyze your usage patterns, preferences, and behavior data to create highly personalized experiences that adapt to your individual interests and gaming style. This includes customizing the types of quests and challenges presented to you, recommending businesses and locations that align with your preferences, and adjusting difficulty levels based on your activity history and capabilities.

Your biometric and wellness data from the wristband helps us provide personalized health insights, set appropriate fitness goals, and create challenges that match your physical activity levels. We use this information to ensure that health-related quests are safe and achievable for your individual fitness profile.

Business Revenue Generation
A significant portion of our data usage supports our revenue-generating business model, which creates value for local businesses while funding the free-to-play aspects of our platform. We use your location and movement data to drive foot traffic to partner businesses by creating location-based quests and challenges that encourage visits to specific venues.

Your review and rating data provides valuable market research and customer feedback to businesses, who pay premium rates for access to authentic, verified reviews from real customers. We aggregate and analyze customer behavior patterns to provide businesses with insights about consumer preferences, peak visitation times, and demographic trends that help them optimize their operations and marketing strategies.

We use your engagement data to help brands and businesses place targeted experiences, promotional content, and exclusive offers in high-traffic areas where they are most likely to reach interested customers. This targeted placement generates revenue while providing users with relevant opportunities and rewards.

Platform Security and Fraud Prevention
We process your personal data to maintain the security and integrity of our platform, preventing fraud, abuse, and unauthorized access. Your location data helps us detect suspicious activity, such as impossible travel patterns that might indicate account compromise or attempts to game the reward system through location spoofing.

Device information and usage patterns help us identify and prevent automated bot activity, multiple account creation, and other forms of platform abuse that could undermine the fairness of our gaming ecosystem. We analyze transaction data to detect fraudulent purchases and protect both users and our business from financial crimes.

Communication and Customer Support
We use your contact information to send important updates about platform changes, security notifications, and service announcements that affect your account or gaming experience. This includes notifications about new features, changes to terms of service, and technical maintenance that may impact service availability.

When you contact customer support, we use your communication data and account information to provide personalized assistance, troubleshoot technical issues, and resolve disputes or concerns about your account or gaming experience.

Legal Compliance and Business Operations
We process personal data as necessary to comply with legal obligations, including tax reporting requirements, regulatory compliance in jurisdictions where we operate, and responses to lawful requests from government authorities. Your data may also be used in legal proceedings to protect our rights, defend against claims, or enforce our terms of service.

For business operations, we analyze aggregated user data to make strategic decisions about platform development, resource allocation, and expansion into new geographic markets. This analysis helps us understand user engagement trends, identify popular features, and plan improvements to the platform.

Research and Development
We use anonymized and aggregated data to conduct research that improves our services and develops new features. This includes analyzing movement patterns to optimize quest placement, studying user engagement to improve game mechanics, and researching health and wellness trends to enhance our fitness-related features.

Your feedback and usage data inform our product development roadmap, helping us prioritize new features and improvements that will provide the most value to our user community.

4. Who We Share Personal Data With
We share your personal information with carefully selected third parties who help us operate our platform, provide services, and deliver value to both users and business partners. All data sharing is conducted under strict contractual agreements that require recipients to protect your information and use it only for specified purposes.

Business Partners and Venue Operators
We share relevant customer data with local businesses, restaurants, retailers, and venue operators who participate in our location-based gaming ecosystem. This sharing is fundamental to our business model and provides value to both users and businesses. When you check in at partner locations, complete quests at their venues, or leave reviews, we share your engagement data, review content, and aggregated visit patterns with these businesses.

Business partners receive anonymized analytics about customer traffic patterns, peak visitation times, demographic trends, and customer satisfaction metrics derived from user reviews and ratings. This information helps businesses optimize their operations, improve customer service, and make data-driven decisions about marketing and promotions.

We also share individual user data with businesses when users explicitly engage with location-based promotions, claim rewards, or participate in business-sponsored challenges. This enables businesses to fulfill rewards, provide personalized offers, and engage directly with customers who have shown interest in their services.

Technology Service Providers
We work with various technology companies that provide essential infrastructure and services for our platform. Cloud computing providers store and process your data on secure servers, while content delivery networks ensure fast and reliable access to our services worldwide. These providers are bound by strict data processing agreements and are only permitted to access your information as necessary to provide their specific services.

Analytics and data processing companies help us analyze user behavior, optimize platform performance, and generate insights that improve the user experience. These partners receive aggregated or pseudonymized data that cannot be directly linked to individual users, except where necessary for specific technical functions.

Payment Processors and Financial Services
When you make purchases through our platform, including $LIVE token acquisitions or wristband orders, we share necessary transaction information with payment processors, banks, and financial service providers. This includes billing information, payment method details, and transaction amounts required to process your purchases securely.

These financial partners are subject to strict regulatory requirements and industry standards for data protection, including PCI DSS compliance for payment card data. We do not store sensitive financial information on our own systems, instead relying on these specialized providers to handle payment processing securely.

Marketing and Advertising Partners
We share aggregated user data and anonymized insights with marketing and advertising partners who help us reach potential new users and promote our services. This includes demographic information, usage patterns, and engagement metrics that help optimize our marketing campaigns and measure their effectiveness.

For users who opt in to personalized advertising, we may share relevant preference data with advertising networks to deliver more targeted and relevant promotional content. This sharing is always subject to user consent and can be disabled through privacy settings in your account.

Legal and Regulatory Authorities
We may share your personal information with law enforcement agencies, regulatory bodies, and government authorities when required by law or when we believe in good faith that disclosure is necessary to comply with legal obligations. This includes responding to court orders, subpoenas, search warrants, and other lawful requests for information.

We may also share information to protect our legal rights, investigate potential violations of our terms of service, prevent fraud or security threats, or protect the safety and rights of our users and the general public. In such cases, we will only share the minimum amount of information necessary to address the specific legal or safety concern.

Corporate Transactions and Business Transfers
In the event of a merger, acquisition, sale of assets, or other corporate transaction involving LivLive or its parent companies, your personal information may be transferred to the acquiring entity as part of the business assets. We will provide notice of such transfers and ensure that the receiving party agrees to protect your information under terms substantially similar to this privacy policy.

Research and Academic Institutions
We may share anonymized and aggregated data with academic researchers, public health organizations, and research institutions for studies related to urban mobility, public health, consumer behavior, and location-based technologies. This data sharing contributes to scientific research and public knowledge while protecting individual privacy through anonymization and aggregation techniques.

Third-Party Integrations and Connected Services
When you choose to connect your LivLive account with third-party services such as social media platforms, fitness tracking apps, or other gaming platforms, we share relevant data as necessary to enable these integrations. The scope of data sharing depends on the specific integration and the permissions you grant when connecting these services.

Data Processors and Vendors
We engage various vendors and service providers who process personal data on our behalf to support our business operations. This includes customer support platforms, email marketing services, data backup providers, and software development contractors. All such vendors are required to sign data processing agreements that strictly limit their use of your information to the specific services they provide to us.

Anonymized and Aggregated Data Sharing
We regularly share anonymized and aggregated data that cannot be linked to individual users with various partners, researchers, and industry organizations. This includes statistical information about user behavior, platform usage trends, and demographic insights that provide value to the broader ecosystem while protecting individual privacy.

Such anonymized data sharing helps improve location-based services industry-wide, contributes to urban planning and public policy research, and enables us to benchmark our platform performance against industry standards.

5. Cookies and Tracking Technologies
We use cookies, web beacons, mobile identifiers, and similar tracking technologies to enhance your experience on our platform, analyze usage patterns, and provide personalized content and features.

Types of Cookies and Tracking Technologies We Use
Essential Cookies are necessary for our website and mobile application to function properly. These cookies enable core functionality such as user authentication, session management, security features, and basic navigation. Essential cookies cannot be disabled without significantly impacting your ability to use our services, and they do not require your consent as they are strictly necessary for service provision.

Performance and Analytics Cookies help us understand how users interact with our platform by collecting information about page visits, feature usage, error messages, and performance metrics. We use this data to identify areas for improvement, optimize loading times, and enhance overall user experience. These cookies collect aggregated data that cannot identify individual users.

Functionality Cookies remember your preferences and settings to provide a more personalized experience. This includes language preferences, display settings, notification preferences, and other customization options you select. These cookies help us maintain your preferred experience across different sessions and devices.

Advertising and Marketing Cookies are used to deliver relevant advertisements and measure the effectiveness of our marketing campaigns. These cookies track your interests and browsing behavior to show you personalized content and advertisements both on our platform and on third-party websites. They also help us avoid showing you the same advertisements repeatedly.

Social Media Cookies enable integration with social media platforms, allowing you to share content, connect your accounts, and interact with social features within our platform. These cookies are set by third-party social media providers and are subject to their respective privacy policies.

Mobile Application Tracking
Our mobile application uses device identifiers, including advertising IDs (such as Apple's IDFA and Google's Advertising ID), to provide similar functionality to web cookies. These identifiers help us analyze app usage, deliver personalized content, and measure the effectiveness of our mobile marketing campaigns.

We also collect mobile-specific data such as device type, operating system version, app version, and usage analytics to optimize performance and compatibility across different mobile devices and platforms.

Location Tracking and Geofencing
As a location-based platform, we use advanced location tracking technologies including GPS, Wi-Fi positioning, cellular triangulation, and Bluetooth beacons to provide core gaming features. We implement geofencing technology to detect when you enter or exit specific geographic areas, triggering location-based quests, rewards, and notifications.

Location tracking is essential to our service and enables features such as real-time quest updates, proximity-based social interactions, and verification of physical presence for reward claiming. This tracking continues while our mobile application is active, even when running in the background.

Cross-Device Tracking
We may link your activity across multiple devices (such as your smartphone, tablet, and computer) to provide a seamless experience and maintain continuity in your gaming progress. This cross-device tracking helps us synchronize your account data, preferences, and achievements across all platforms where you access LivLive services.

Third-Party Tracking and Analytics
We partner with third-party analytics providers, including Google Analytics, Facebook Analytics, and specialized mobile analytics platforms, to gain deeper insights into user behavior and platform performance. These services may use their own cookies and tracking technologies, subject to their respective privacy policies.

We also work with attribution partners who help us understand which marketing channels and campaigns are most effective at attracting new users. These partners may track user interactions across multiple websites and applications to provide comprehensive attribution analysis.

Managing Your Cookie and Tracking Preferences
Web Browser Controls: Most web browsers allow you to control cookies through their settings. You can typically choose to accept all cookies, reject all cookies, or receive notifications when cookies are being set. However, disabling essential cookies may prevent you from using certain features of our website.

Mobile Device Settings: On mobile devices, you can control advertising tracking through your device settings. iOS users can enable "Limit Ad Tracking" in their privacy settings, while Android users can opt out of ads personalization in their Google account settings.

LivLive Privacy Settings: Within your LivLive account settings, you can control various privacy and tracking preferences, including:

Personalized advertising preferences

Analytics data sharing options

Social media integration settings

Location tracking precision levels

Cross-device synchronization preferences

Opt-Out Tools: We provide links to industry opt-out tools and resources that allow you to control tracking by advertising networks and analytics providers. These include the Digital Advertising Alliance's opt-out page and the Network Advertising Initiative's consumer choice tools.

Data Retention for Tracking Information
Cookie data and tracking information are retained for varying periods depending on their purpose and type. Essential cookies are typically session-based and expire when you close your browser, while persistent cookies may remain on your device for up to two years. Analytics data is generally retained for 26 months, while advertising data may be retained for up to 13 months.

You can clear cookies and tracking data at any time through your browser or device settings, though this may require you to re-enter preferences and login information when you next visit our platform.

6. Your Rights Over Your Personal Data
We respect your privacy rights and provide you with various controls over your personal information. Depending on your location and applicable privacy laws, you may have specific legal rights regarding your personal data that we are committed to honoring.

Right to Access Your Data
You have the right to request access to the personal information we hold about you. This includes the right to obtain confirmation of whether we are processing your personal data, and if so, to receive a copy of that data along with information about how it is being used. You can access much of your personal information directly through your LivLive account dashboard, which provides real-time access to your profile information, activity history, location data, and privacy settings.

For more comprehensive data access requests, you can contact us using the information provided in the Contact section of this policy. We will respond to access requests within 30 days and provide the information in a commonly used, machine-readable format when technically feasible.

Right to Correct or Update Your Data
You have the right to request correction of inaccurate or incomplete personal information. Most of your profile information can be updated directly through your account settings, including your name, email address, phone number, and profile preferences. For wristband data or system-generated information that cannot be directly edited, you can contact our support team to request corrections.

We encourage you to keep your information current and accurate, as this helps us provide better services and ensures that communications and rewards reach you properly. When you update your information, changes are typically reflected across our systems within 24 hours.

Right to Delete Your Data
You have the right to request deletion of your personal information under certain circumstances. This includes situations where the data is no longer necessary for the purposes for which it was collected, where you withdraw consent for processing, or where the data has been unlawfully processed.

You can delete your LivLive account at any time through your account settings, which will initiate the deletion process for most of your personal data. However, some information may be retained for legitimate business purposes, such as transaction records for tax and accounting purposes, or as required by law.

Please note that deleting your account will result in the permanent loss of your gaming progress, achievements, $LIVE token balance, and social connections within the platform. This action cannot be undone, so we recommend carefully considering this decision and potentially downloading your data first.

Right to Restrict Processing
You have the right to request restriction of processing of your personal data in certain circumstances, such as when you contest the accuracy of the data, when processing is unlawful but you prefer restriction over deletion, or when you need the data for legal claims but we no longer need it for our purposes.

When processing is restricted, we will continue to store your data but will not process it further without your consent, except for storage purposes or to establish, exercise, or defend legal claims.

Right to Data Portability
Where technically feasible, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another service provider. This right applies to data you have provided to us and that we process based on your consent or for the performance of our contract with you.

We provide data export functionality through your account settings, allowing you to download your profile information, activity history, and other personal data. For more comprehensive data portability requests, please contact our support team.

Right to Object to Processing
You have the right to object to certain types of processing of your personal data, particularly for direct marketing purposes or when processing is based on legitimate interests. You can opt out of marketing communications at any time through your account settings or by using the unsubscribe links in our emails.

For processing based on legitimate interests, you can object by contacting us with specific reasons related to your particular situation. We will stop processing your data unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

Right to Withdraw Consent
Where we process your personal data based on your consent, you have the right to withdraw that consent at any time. This includes consent for location tracking, marketing communications, data sharing with partners, and other optional features. Withdrawing consent will not affect the lawfulness of processing based on consent before its withdrawal.

You can manage your consent preferences through your account privacy settings, where you can enable or disable various types of data processing and sharing.

Rights Related to Automated Decision Making
If we use automated decision-making processes that significantly affect you, you have the right to request human intervention, express your point of view, and contest the decision. Currently, our platform uses automated systems for quest recommendations, reward calculations, and fraud detection, but these systems do not make decisions that significantly affect your legal rights or similar interests.

How to Exercise Your Rights
To exercise any of these rights, you can:

Use Your Account Settings: Many rights can be exercised directly through your LivLive account dashboard, including updating information, managing privacy preferences, downloading data, and deleting your account.

Contact Customer Support: For more complex requests or rights that cannot be exercised through your account settings, contact us at contact@livlive.com with your specific request and any necessary verification information.

Submit a Formal Request: For formal data subject requests, particularly those related to legal compliance, you may submit detailed written requests that include your full name, account information, specific rights you wish to exercise, and any supporting documentation.

Response Times and Verification
We will respond to rights requests within 30 days of receipt, though complex requests may require up to 90 days with appropriate notification of the extension. We may request additional information to verify your identity before processing requests that involve access to or deletion of personal data.

For security purposes, we will only respond to requests from the email address associated with your account or through verified account access. If you no longer have access to your account email, additional verification steps may be required.

Limitations and Exceptions
Some rights may be limited by applicable law or legitimate business interests. For example, we may retain certain data for legal compliance, fraud prevention, or to complete transactions you have initiated. We will explain any limitations when responding to your requests and provide information about your options for appeal or complaint to relevant supervisory authorities.

6.1 Data Retention & Deletion
How long we keep your data – We apply purpose-based schedules:

Account & profile – retained while you have an active account plus 90 days, then deleted or anonymised.

Location, wrist-band & AR telemetry – 18 months rolling window, then aggregated and de-identified.

Transactional records – 7 years (statutory accounting).

Support tickets & legal records – as long as required to resolve the issue or satisfy applicable limitation periods.

Permanent deletion – When you hit Delete Account, we:

Place the account in a 14-day reversible “grace” state.

Wipe personally identifiable fields from active systems after the grace period.

Purge encrypted back-ups during their next rotation cycle (max 30 days later).

7. How We Protect Your Personal Data
We implement comprehensive security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. Our security approach combines technical, administrative, and physical safeguards designed to maintain the confidentiality, integrity, and availability of your data.

Technical Security Measures
Encryption: We use industry-standard encryption protocols to protect your data both in transit and at rest. All data transmitted between your devices and our servers is encrypted using TLS (Transport Layer Security) 1.3 or higher. Personal data stored in our databases is encrypted using AES-256 encryption, with encryption keys managed through secure key management systems that are separate from the encrypted data.

Access Controls: We implement strict access controls that limit employee and contractor access to personal data based on job responsibilities and the principle of least privilege. All access to personal data is logged and monitored, with regular audits to ensure compliance with our access policies. Multi-factor authentication is required for all administrative access to systems containing personal data.

Network Security: Our infrastructure is protected by enterprise-grade firewalls, intrusion detection systems, and network monitoring tools that continuously scan for suspicious activity and potential security threats. We use network segmentation to isolate sensitive systems and implement regular penetration testing to identify and address potential vulnerabilities.

Data Anonymization and Pseudonymization: Where possible, we use anonymization and pseudonymization techniques to reduce privacy risks while maintaining the utility of data for analytics and service improvement. Personal identifiers are separated from behavioral data, and we use hashing and tokenization to protect sensitive information in our systems.

Administrative Security Measures
Employee Training and Background Checks: All employees and contractors with access to personal data undergo comprehensive privacy and security training, including specific training on data handling procedures, incident response, and regulatory compliance requirements. We conduct background checks for employees in sensitive positions and require all staff to sign confidentiality agreements.

Privacy by Design: We incorporate privacy considerations into our product development process from the earliest stages, ensuring that new features and systems are designed with appropriate privacy protections. This includes conducting privacy impact assessments for new data processing activities and implementing privacy-preserving technologies where feasible.

Vendor Management: Third-party service providers who process personal data on our behalf are required to maintain security standards equivalent to our own. We conduct due diligence reviews of vendor security practices, require contractual commitments to data protection, and regularly audit vendor compliance with our security requirements.

Incident Response: We maintain a comprehensive incident response plan that includes procedures for detecting, investigating, and responding to potential data breaches or security incidents. Our incident response team is trained to quickly assess and contain security threats while minimizing impact on users and ensuring appropriate notification of affected individuals and regulatory authorities.

Physical Security Measures
Data Center Security: Our primary data processing infrastructure is hosted in certified data centers that maintain strict physical security controls, including 24/7 monitoring, biometric access controls, environmental controls, and redundant power and network connections. These facilities are certified under industry standards such as SOC 2 Type II and ISO 27001.

Device and Equipment Security: Company devices used to access personal data are secured with encryption, remote wipe capabilities, and endpoint protection software. Physical access to offices and facilities where personal data may be accessed is controlled through keycard systems and visitor management procedures.

Data Backup and Recovery
We maintain secure, encrypted backups of personal data to ensure business continuity and data recovery in the event of system failures or disasters. Backup systems are subject to the same security controls as production systems, with regular testing of recovery procedures to ensure data can be restored quickly and accurately when needed.

Backup data is stored in geographically distributed locations to protect against regional disasters, with retention periods that align with our data retention policies and legal requirements.

Monitoring and Auditing
Continuous Monitoring: We employ automated monitoring systems that track access to personal data, detect unusual activity patterns, and alert security teams to potential threats in real-time. This includes monitoring for unauthorized access attempts, data exfiltration, and other suspicious behaviors.

Regular Security Audits: We conduct regular internal security audits and engage third-party security firms to perform independent assessments of our security controls. These audits help identify potential vulnerabilities and ensure that our security measures remain effective against evolving threats.

Compliance Monitoring: We maintain ongoing monitoring of our compliance with applicable privacy regulations and industry standards, including regular reviews of our data processing activities, consent management, and user rights fulfillment procedures.

Vulnerability Management
We maintain a comprehensive vulnerability management program that includes regular security scanning, patch management, and security testing of our applications and infrastructure. Critical security updates are applied promptly, and we maintain relationships with security researchers through responsible disclosure programs.

Data Minimization and Retention Controls
As part of our security approach, we implement data minimization principles that limit the collection and retention of personal data to what is necessary for our business purposes. Automated data retention policies ensure that personal data is deleted or anonymized when it is no longer needed, reducing the overall risk exposure.

Security Incident Notification
In the event of a security incident that may affect your personal data, we will notify affected users and relevant regulatory authorities in accordance with applicable legal requirements. Notifications will include information about the nature of the incident, the types of data involved, the steps we are taking to address the incident, and recommendations for protecting yourself from potential harm.

Limitations of Security Measures
While we implement robust security measures, no system is completely secure, and we cannot guarantee absolute security of your personal data. We encourage users to take their own precautions, such as using strong, unique passwords, enabling two-factor authentication where available, and being cautious about sharing personal information in public forums or with other users.

7.1 Children’s Privacy
LivLive is not directed to children under 18 and we do not knowingly collect personal data from anyone under that age. If we learn that a minor has created an account, we will delete it and erase associated data without undue delay. Parents who believe their child has provided data should e-mail contact@livlive.com to request removal.

8. International Transfers of Personal Data
As a global platform, LivLive processes and stores personal data in multiple countries to provide our services efficiently and effectively to users worldwide. This section explains how we handle international transfers of your personal information and the safeguards we implement to protect your data across borders.

Geographic Distribution of Data Processing
Our primary data processing operations are distributed across several jurisdictions to ensure optimal performance and reliability of our services. Personal data may be transferred to and processed in the United States, European Union member states, Singapore, and other countries where our service providers and business partners operate.

The specific locations where your data is processed may vary depending on your geographic location, the services you use, and operational requirements such as load balancing and disaster recovery. We maintain data processing facilities and partnerships in regions that provide strong legal frameworks for data protection and privacy rights.

Legal Basis for International Transfers
Adequacy Decisions: Where possible, we transfer personal data to countries that have been recognized by relevant authorities (such as the European Commission) as providing adequate levels of data protection. These adequacy decisions provide a legal basis for data transfers without requiring additional safeguards.

Standard Contractual Clauses: For transfers to countries without adequacy decisions, we use Standard Contractual Clauses (SCCs) approved by relevant data protection authorities. These clauses provide contractual guarantees that personal data will be protected according to European standards regardless of the destination country's local laws.

Binding Corporate Rules: Within our corporate group, we implement Binding Corporate Rules that establish consistent data protection standards across all entities and jurisdictions where we operate. These rules ensure that your personal data receives equivalent protection regardless of which LivLive entity processes it.

Specific Transfer Scenarios
Cloud Infrastructure: We use cloud computing services provided by major technology companies that operate data centers worldwide. These providers have implemented comprehensive data protection measures and offer data residency options that allow us to control where your data is stored and processed.

Business Partners: When sharing data with local business partners and venue operators, transfers typically occur within the same geographic region where you use our services. However, some business partners may be part of international chains or franchises that process data across multiple countries.

Payment Processing: Financial transactions may involve international transfers to payment processors, banks, and financial institutions that operate globally. These transfers are necessary to process payments and are subject to strict financial industry regulations and security standards.

Customer Support: Our customer support operations may involve transfers to support centers in different countries to provide 24/7 assistance in multiple languages. Support staff access only the minimum personal data necessary to resolve your inquiries.

Data Localization and Residency Options
Where required by local law or user preference, we offer data localization options that keep your personal data within specific geographic boundaries. This includes:

Regional Data Centers: We maintain data processing facilities in major geographic regions, allowing us to store and process data locally where required by law or preferred by users.

Data Residency Controls: Enterprise and premium users may have access to data residency controls that allow them to specify preferred geographic locations for data storage and processing.

Local Processing: For certain types of sensitive data, such as biometric information from wristbands, we may implement local processing capabilities that minimize the need for international transfers.

Safeguards for International Transfers
Encryption in Transit: All international data transfers are encrypted using strong encryption protocols that protect data confidentiality during transmission across international networks.

Transfer Impact Assessments: We conduct Transfer Impact Assessments (TIAs) to evaluate the privacy risks associated with international transfers and implement additional safeguards where necessary to ensure adequate protection.

Monitoring and Auditing: We maintain ongoing monitoring of international data transfers to ensure compliance with applicable laws and contractual commitments. This includes regular audits of transfer mechanisms and recipient safeguards.

Data Minimization: We minimize international transfers by processing data locally where possible and transferring only the minimum amount of data necessary for specific business purposes.

Government Access and Surveillance
We are committed to protecting your personal data from inappropriate government access and surveillance. When we receive lawful requests for data from government authorities, we:

Challenge Overbroad Requests: We review all government requests for personal data and challenge requests that appear to be overbroad, legally insufficient, or inconsistent with applicable privacy laws.

Transparency Reporting: We publish regular transparency reports that provide aggregate information about government requests for user data, helping users understand the frequency and nature of such requests.

Legal Process Requirements: We require proper legal process (such as court orders or subpoenas) before providing personal data to government authorities, except in emergency situations involving imminent threats to safety.

User Notification: Where legally permitted, we notify users when their personal data has been requested by government authorities, allowing them to seek legal counsel or challenge the request if appropriate.

Cross-Border Data Sharing Controls
Contractual Protections: All international data sharing agreements include specific contractual provisions that require recipients to implement appropriate technical and organizational measures to protect personal data.

Certification and Compliance: We require international partners to maintain relevant privacy and security certifications, such as ISO 27001, SOC 2, or equivalent standards that demonstrate their commitment to data protection.

Regular Reviews: We conduct regular reviews of international data sharing arrangements to ensure they remain appropriate and compliant with evolving privacy laws and regulations.

User Rights in International Transfers
Right to Information: You have the right to information about international transfers of your personal data, including the countries involved and the safeguards implemented to protect your data.

Right to Object: In certain circumstances, you may have the right to object to international transfers of your personal data, particularly where such transfers are based on legitimate interests rather than legal requirements.

Complaint Rights: If you have concerns about international transfers of your personal data, you can file complaints with relevant data protection authorities in your jurisdiction or in the countries where your data is processed.

9. Policy Updates and Changes
We may update this Privacy Policy from time to time to reflect changes in our practices, services, legal requirements, or industry standards. We are committed to providing clear notice of any changes and ensuring that you understand how modifications may affect your privacy rights and our handling of your personal data.

Types of Changes We May Make
Service Evolution Changes: As we develop new features, expand into new geographic markets, or modify existing services, we may need to update this Privacy Policy to reflect new types of data collection, processing activities, or sharing arrangements. These changes help ensure that our privacy practices remain aligned with our service offerings.

Legal and Regulatory Updates: Changes in privacy laws, regulations, or legal interpretations may require us to modify our privacy practices and update this policy accordingly. This includes compliance with new privacy regulations, court decisions, or guidance from regulatory authorities that affect how we handle personal data.

Security and Technology Improvements: As we implement new security measures, adopt new technologies, or change our technical infrastructure, we may update this policy to reflect these improvements and explain how they affect the protection of your personal data.

Business Structure Changes: Corporate transactions such as mergers, acquisitions, or changes in our business structure may necessitate updates to this Privacy Policy to reflect new ownership, data processing arrangements, or corporate relationships.

Notice and Communication of Changes
Advance Notice: For material changes that significantly affect how we collect, use, or share your personal data, we will provide at least 30 days advance notice before the changes take effect. This advance notice period allows you to review the changes and make informed decisions about your continued use of our services.

Multiple Communication Channels: We will notify you of privacy policy changes through multiple channels to ensure you receive the information:

Email notifications sent to your registered email address

In-app notifications displayed prominently when you next use our mobile application

Website banners and notices displayed on our website

Push notifications for significant changes (if you have enabled push notifications)

Clear Change Summaries: Our change notifications will include clear, plain-language summaries of the key modifications, highlighting what has changed and how it may affect you. We will avoid legal jargon and focus on practical implications for users.

Do Not Track signals (U.S.) – We do not respond to browser-initiated Do Not Track signals because there is no uniform industry standard. You may control personalised advertising via the options in Settings › Privacy or through the DAA/NAI opt-out tools linked there.

Your Options When We Make Changes
Continued Use Constitutes Acceptance: By continuing to use LivLive services after the effective date of privacy policy changes, you indicate your acceptance of the updated terms. This is the standard approach for most online services and allows us to implement necessary updates while maintaining service continuity.

Right to Object or Withdraw: For changes that expand our data processing activities or introduce new types of data sharing, you may have the right to object to these changes or withdraw your consent for specific processing activities. We will clearly explain these options in our change notifications.

Account Deletion Option: If you disagree with material changes to our Privacy Policy, you always have the option to delete your account and discontinue use of our services. We will remind you of this option in our change notifications and provide clear instructions for account deletion.

Granular Consent Management: Where possible, we will provide granular controls that allow you to accept some changes while opting out of others. This may include separate consent mechanisms for new marketing practices, data sharing arrangements, or optional features.

Version Control and Historical Access
Version History: We maintain a version history of our Privacy Policy that allows you to review previous versions and understand how our practices have evolved over time. This transparency helps you make informed decisions about your privacy preferences.

Effective Date Tracking: Each version of our Privacy Policy includes clear effective dates and version numbers, making it easy to identify when changes were made and which version applies to your use of our services.

Archive Access: Previous versions of our Privacy Policy remain accessible through our website for at least two years after they are superseded, allowing you to reference historical terms and understand the evolution of our privacy practices.

Emergency Changes
Security-Related Updates: In rare cases involving immediate security threats or legal requirements, we may need to implement privacy policy changes on shorter notice. In such situations, we will provide notice as soon as reasonably possible and explain the urgent circumstances that necessitated the immediate change.

Regulatory Compliance: Changes required for immediate compliance with new laws or regulatory orders may be implemented with reduced notice periods, though we will still strive to provide advance notice whenever possible.

Feedback and Questions About Changes
Comment Period: For significant changes, we may provide a comment period during which users can ask questions, provide feedback, or raise concerns about proposed modifications. While we cannot guarantee that all feedback will result in changes, we carefully consider user input in our decision-making process.

Customer Support: Our customer support team is available to answer questions about privacy policy changes and help you understand how modifications may affect your use of our services. You can contact us at contact@livlive.com with any concerns or questions.

Community Discussion: We may facilitate community discussions about significant privacy policy changes through our official forums, social media channels, or user advisory groups, providing opportunities for broader user engagement and feedback.

Transition Periods
Gradual Implementation: For complex changes that affect multiple aspects of our service, we may implement modifications gradually over a transition period. This approach helps ensure smooth service continuity while allowing users to adapt to new privacy practices.

Legacy Data Handling: When privacy policy changes affect how we handle existing data, we will clearly explain how previously collected information will be treated under the new policy and provide options for users who prefer different handling of their historical data.

Monitoring and Review
Regular Policy Reviews: We conduct regular reviews of our Privacy Policy to ensure it remains accurate, comprehensive, and aligned with our current practices. These reviews help us identify areas for improvement and ensure ongoing compliance with applicable laws.

User Feedback Integration: We actively monitor user feedback, support inquiries, and privacy-related concerns to identify areas where our Privacy Policy may need clarification or modification to better serve user needs and expectations.

10. Contact Information
We are committed to addressing your privacy concerns and questions promptly and thoroughly. Whether you need assistance with your privacy settings, want to exercise your data rights, or have questions about our privacy practices, we provide multiple ways to reach our team.

General Privacy Inquiries
Email Contact: For general privacy questions, policy clarifications, or concerns about our data handling practices, you can reach us at contact@livlive.com. Our privacy team monitors this email address and strives to respond to all inquiries within 48 hours during business days.

Response Times: We aim to provide initial responses to privacy inquiries within 48 hours, with complete responses provided within 30 days for complex requests. During peak periods or for particularly complex inquiries, we may require additional time and will keep you informed of our progress.

Data Subject Rights Requests
Formal Rights Requests: For formal requests to exercise your data subject rights (such as access, correction, deletion, or portability), please use our dedicated privacy request form available through your account settings or contact us directly at contact@livlive.com with "Data Rights Request" in the subject line.

Required Information: To process rights requests efficiently and securely, please include:

Your full name and LivLive username

The email address associated with your account

Specific details about the rights you wish to exercise

Any relevant timeframes or specific data categories involved

Verification information as requested

Identity Verification: For security purposes, we may require additional verification before processing requests that involve access to or deletion of personal data. This may include confirming your identity through your registered email address or providing additional account verification information.

Technical Support and Account Issues
Account-Related Privacy Questions: For questions about privacy settings, account security, or technical issues related to data handling, you can contact our technical support team through the in-app support feature or by emailing contact@livlive.com with "Technical Support" in the subject line.

Wristband Privacy Settings: For questions specific to wristband data collection, sensor settings, or biometric data handling, our technical support team can provide detailed guidance on managing your device privacy preferences and understanding what data is collected by your wristband.

Business and Partnership Inquiries
Business Privacy Questions: If you represent a business partner, venue operator, or potential partner with questions about our data sharing practices, business data handling, or partnership privacy requirements, please contact us at contact@livlive.com with "Business Privacy Inquiry" in the subject line.

Vendor and Service Provider Inquiries: Third-party service providers, vendors, or contractors working with LivLive who have questions about data processing requirements or privacy compliance should contact our business team through the same email address.

Legal and Compliance Matters
Legal Requests: Law enforcement agencies, regulatory authorities, and legal representatives should direct formal requests for user data or compliance information to contact@livlive.com with "Legal Request" in the subject line. All legal requests must include appropriate legal documentation and will be reviewed by our legal team.

Regulatory Inquiries: Data protection authorities, privacy regulators, and other government agencies can contact us regarding compliance matters, investigations, or regulatory guidance requests through our general contact email with appropriate identification of their authority and purpose.

Corporate Contact Information
LivLive Inc.
55th street East, P.H. SL55 Building, Floor 21, Suite 3, Panama City, Republic of Panama
Primary contact for token-related privacy matters and overall platform privacy policies

Response and Escalation Procedures
Initial Response: All privacy-related inquiries receive an initial acknowledgment within 48 hours, confirming receipt of your request and providing an estimated timeline for a complete response.

Escalation Process: If you are not satisfied with our initial response or need to escalate a privacy concern, you can request escalation to our senior privacy team by replying to our response with "Escalation Request" in the subject line.

External Complaints: If you believe we have not adequately addressed your privacy concerns, you have the right to file complaints with relevant data protection authorities in your jurisdiction. We will provide information about relevant authorities and complaint procedures upon request.

Language and Accessibility
Language Support: We provide privacy support in multiple languages to serve our global user base. If you prefer to communicate in a language other than English, please indicate your preferred language in your initial contact, and we will arrange for appropriate language support.

Accessibility Accommodations: We are committed to making our privacy support accessible to users with disabilities. If you need accommodations to communicate with us about privacy matters, please let us know your specific needs, and we will work to provide appropriate assistance.



11. California Privacy Notice (CCPA/CPRA)
California residents have the following additional rights:

Right to know / access – categories & specific pieces of personal information collected in the preceding 12 months.

Right to delete – request we erase personal information subject to statutory exemptions.

Right to correct – inaccurate personal information.

Right to opt-out of “sale” or “sharing” – You may disable cross-context behavioural advertising at any time in Settings › Privacy › California Privacy Controls or via a browser GPC signal.

Right to limit use of sensitive information – LivLive uses sensitive data only to deliver core functionality (location-based quests) and does not disclose it for other purposes.

We do not use or disclose personal information for automated decision-making with legal or similarly significant effects. We do not knowingly “sell” or “share” the personal information of minors under 16.

12. Conclusion
This Privacy Policy, last revised on 5 September 2025, represents our commitment to transparency, user control, and responsible data handling in the operation of our location-based gaming platform. We recognize that privacy is fundamental to user trust and are dedicated to maintaining the highest standards of data protection while delivering innovative services that enhance your real-world experiences.

By using LivLive services, you become part of a community that values both technological innovation and privacy protection. We encourage you to take an active role in managing your privacy by regularly reviewing your account settings, understanding how your data is used, and contacting us with any questions or concerns.

We will continue to evolve our privacy practices in response to technological advances, regulatory changes, and user feedback, always with the goal of providing you with greater control over your personal information while enabling the exciting location-based experiences that make LivLive unique.

Thank you for trusting us with your personal information and for being part of the LivLive community.