PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy (the “Policy”) explains how Livialink Global Concept, Registration No. RC 2417377, Nigeria, processes users’ personal data through https://www.jovepay.com (the “Website”).

This Policy explains the types of personal data we collect or otherwise process, how and why we use that information, the purposes for which it is required, and the rights available to you in relation to your personal data.

For the purposes of this Policy, personal data means information that can identify you either directly or indirectly, or information that can be used to contact you. This Policy applies to personal information that you provide to us or that we obtain from our partners. It does not apply to information that has been anonymized so that it can no longer reasonably be used to identify you.

DISCLAIMER

Please read this Policy carefully before using our Website or Services. By accepting this Policy, you acknowledge that you are legally bound by its terms and any provisions incorporated into it.

If you do not agree with this Policy or any of its provisions, you should immediately stop using the Website and our Services.

Our Website and Services are not intended for individuals under the age of 18. We do not knowingly collect or process personal information belonging to children under 18.

If we discover that we have collected personal data relating to an individual under 18, we will take reasonable steps to delete that information once we become aware of it. We may also restrict or prevent the individual from accessing our Services and, where necessary and legally appropriate, seek parental consent for the collection, use, or disclosure of the child's personal information.

If you believe that we may have collected personal data relating to a person under 18, please notify us immediately.

We may amend this Privacy Policy periodically. We encourage you to review this Policy from time to time to remain informed about how we handle personal data. Your continued use of our Services after changes have been published constitutes acceptance of the updated Policy.

Where applicable law requires us to obtain your affirmative consent to material changes, you may be unable to continue using our Services if you decline to provide that consent.

WHO PROCESSES PERSONAL DATA?

Livialink Global Concept, Registration No. RC 2417377, Nigeria (hereinafter referred to as “Livialink Global Concept,” “we,” “us,” or “our”) is responsible for processing personal data in connection with the Website and Services.

If you have questions regarding this Privacy Policy or the processing of your personal data, you may contact us by email at:

[email protected]

WHEN IS PERSONAL DATA PROCESSED?

Personal data may be processed when you use the Website, interact with our APIs or third-party services made available through the Website, use our payment processing services, or interact with our marketing communications, including marketing emails.

Together, these activities are referred to as the “Services.”

DEFINITIONS

“Processing”

Processing means any operation or series of operations performed on personal data, whether manually or through automated means. This includes collecting, recording, organizing, storing, updating, retrieving, using, transferring, distributing, providing access to, anonymizing, restricting, deleting, or destroying personal data in accordance with this Policy and applicable law.

“User” or “Users”

A User means an individual who visits the Website, uses our Services, or an individual acting on behalf of one of our commercial customers.

“Personal Data”

Personal Data means information relating to an identifiable individual or information that can be used to identify an individual.

“Cookies”

Cookies are small pieces of data sent by a web server and stored on a user's device. Cookies may be placed on your device when you visit the Website and may help us operate the Website effectively, remember your preferences, such as language settings, and understand Website traffic and usage.

“Party”

A Party refers to either you or us. For purposes of this Policy, the contracting parties are you and Livialink Global Concept.

“Services”

Services means the services provided by Livialink Global Concept through the Website and associated systems, APIs, and services.

WHAT GUARANTEES DO WE PROVIDE?

We apply appropriate safeguards when processing Personal Data. Livialink Global Concept takes reasonable organizational and technical measures designed to protect Users' Personal Data against unauthorized access, loss, misuse, alteration, disclosure, or destruction.

We do not knowingly process special categories of Personal Data, such as information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, except where such processing is legally required or otherwise permitted by applicable law.

Automated decision-making (ADM) may be used in connection with certain Services to help streamline processes. For example, automated systems may be used to assess the accuracy or consistency of information provided by Users.

Where automated decision-making is used, it is not intended to produce legal effects concerning you. Where applicable, you may challenge a decision resulting from an automated process by contacting us.

We do not sell Users' Personal Data in exchange for monetary compensation.

WHAT PERSONAL DATA DO WE PROCESS?

Depending on how you interact with our Website and Services, we may process the following categories of Personal Data:

• Account registration information: full name, email address, website URL, business sector, and occupation.
• Transaction information: wallet address required to execute transactions, bank account information, address, and age.
• Identification information: passport information, telephone number, photographs, and other documents that may be requested for identification purposes.
• KYC information: identity documents, biometric information, liveness verification and facial matching information, and AML screening results. Additional or mandatory KYC requirements may apply to certain categories of Users, and affected Users will be informed in advance where applicable.
• Communication information: name, email address, or telephone number where you have agreed to receive communications from us.
• Technical information: IP address, language preference, country, browser type and version, browser plug-in information, location information, operating system, and operating system version.
• Usage information: URL clickstreams, page response times, download errors, time spent on Website pages, and activities performed on Website pages.
• Cookie information: information collected through cookies and similar technologies.

WHY DO WE COLLECT AND PROCESS PERSONAL DATA?

We may process your Personal Data for the following purposes:

• To conduct statistical and analytical activities and understand how Users interact with our Website and Services.
• To provide technical and customer support.
• To maintain, improve, and optimize the Website and its functionality.
• To analyze how Users interact with different pages and features of the Website.
• To authenticate Users when they access the Website or create an account.
• To communicate with Users when they contact us, submit inquiries, or request assistance.
• To send newsletters, service updates, and other communications where permitted and, where required, with your consent.
• To execute transactions and provide our Services.
• To conduct KYC and AML procedures where required.
• To comply with applicable legal and regulatory obligations.
• To protect the security and integrity of our Website, systems, Services, and Users.
• To detect, prevent, and investigate fraud or other unlawful activity.

WHAT LEGAL GROUNDS DO WE USE TO PROCESS PERSONAL DATA?

We process Personal Data on the following legal bases, where applicable:

Your Consent

We may process your Personal Data based on your explicit consent. Consent may be obtained through consent forms, notices, or other mechanisms incorporated into our Services.

Contractual Necessity

We may need to process certain Personal Data to perform our contractual obligations to you or to take steps at your request before entering into a contract.

Legitimate Interests

We may process Personal Data where necessary for our legitimate interests, provided that those interests do not override your applicable rights and freedoms.

Our legitimate interests may include:

• Conducting market research.
• Improving and developing our Services.
• Protecting and enforcing our legal rights.
• Marketing and promoting our Services where legally permitted.
• Maintaining Website and system security.
• Detecting and preventing fraud.
• Protecting Users and our business operations.

DATA CATEGORIES, PURPOSES AND LEGAL GROUNDS

COOKIES

Cookies may be used when Users are logged into their accounts so that the Website can recognize and authenticate them. This means that Users may not need to sign in again each time they navigate to another page.

Authentication-related cookies may be deleted or cleared when you log out. This helps ensure that restricted features and areas remain accessible only to authenticated Users.

When you submit information through a form, such as a contact form or comment field, cookies may be used to remember certain information for future correspondence or interactions.

Some cookies may be persistent, meaning that they remain stored on your device for a specified period. Certain persistent cookies may remain on your device for up to one year.

In some circumstances, service providers may use information you provide, either directly or indirectly, including information associated with a connected social media account, to provide content that may be relevant to your interests.

Types of Cookies

Necessary Cookies

Necessary cookies support essential Website functionality, including page navigation and access to secure areas.

Without these cookies, certain portions of the Website may not operate correctly. These cookies may also record whether a visitor has accepted a particular cookie category through the cookie consent mechanism.

Where applicable, these cookies may support compliance with applicable data protection requirements.

Statistics Cookies

Statistics cookies help us understand how visitors interact with the Website by collecting and reporting information about Website usage.

These cookies may collect information about visitor behavior and interactions with various Website features, including real-time pricing or related information displayed on the Website.

Marketing Cookies

Marketing cookies may be used to track visitors across different websites.

Their purpose may include helping display advertisements or promotional content that is more relevant and engaging to individual Users and providing greater value to publishers and third-party advertisers.

Third-party service providers may also place cookies on the Website in certain circumstances.

Third-party analytics tools may help us measure and understand Website usage so that we can continue improving our content and Services. These tools may collect information such as how long Users spend on the Website and which pages they visit.

We may periodically test new features or make changes to how the Website is presented or delivered. During these periods, cookies may help us provide Users with a consistent experience.

PROCESSING OF MERCHANT CUSTOMERS' DATA

Where a User acts as a Merchant, the Merchant is responsible for determining the personal data requirements applicable to each of its customers and complying with those requirements.

Where required by applicable data protection legislation, the Merchant must obtain the appropriate consent from its customers or establish another valid legal basis for collecting, storing, and processing their customers' Personal Data, including where such processing involves the use of our Services.

The Merchant is responsible for ensuring that its customers receive appropriate information regarding the processing of their Personal Data and, where required, consent to the transfer of their Personal Data to Livialink Global Concept.

The Merchant is responsible for complying with applicable data protection requirements relating to its customers and must provide customers with any information required by applicable law concerning Livialink Global Concept and the processing or transfer of their Personal Data.

The Merchant must implement and maintain appropriate organizational and technical safeguards designed to protect its customers' Personal Data.

If a Merchant violates applicable data protection legislation and that violation causes losses or liabilities to Livialink Global Concept, the Merchant may be responsible for such losses to the extent permitted by applicable law and the applicable agreement between the parties.

THIRD-PARTY SERVICE PROVIDERS

In certain circumstances, we may need to share Personal Data with trusted third-party service providers.

We may share Personal Data with contractors and service providers where those parties are subject to appropriate confidentiality or data protection obligations concerning the Personal Data they process.

Depending on the circumstances, Personal Data may be disclosed to:

• Companies within our corporate group or subsidiaries, where applicable.
• Government authorities and law enforcement agencies.
• Regulatory, enforcement, exchange, central or local government bodies.
• Courts and other statutory or public authorities.
• Business partners.
• Suppliers and contractors.
• Sponsors.
• Analytics providers.
• Search engine providers.
• Other service providers necessary to operate or improve our Services.

We may disclose or share Personal Data for purposes including:

• Providing and administering our Services.
• Complying with applicable laws, regulations, court orders, and legal requirements.
• Detecting, investigating, and preventing fraudulent or unlawful activity.
• Responding to claims, investigations, legal proceedings, or other lawful processes.
• Preventing or stopping activities that we reasonably believe are illegal, unethical, unlawful, or otherwise actionable.
• Protecting the safety of you, another person, or the public.
• Completing a merger, acquisition, restructuring, reorganization, transfer of control, or similar corporate transaction, including transferring relevant information to the applicable third party where legally permitted or where your consent is required.

We may also share anonymous, aggregated, or otherwise non-identifying information for analytical and research purposes.

If you would like information about the third parties with whom your Personal Data may be shared, you may contact us at:

[email protected]

The specific third parties involved may vary depending on the particular Services you use.

YOUR RIGHTS UNDER THIS POLICY

Depending on applicable law, you may have the following rights concerning your Personal Data:

Right of Access

You may request information about the Personal Data we hold about you, including how we use it and the purposes for which it is processed.

Right to Correct

You may request that we correct, update, restrict, or delete Personal Data where it is incomplete, inaccurate, outdated, unlawfully obtained, or no longer necessary for the relevant processing purpose, subject to applicable legal requirements.

Right to Delete

You may request deletion of the Personal Data we hold about you, subject to applicable legal and regulatory requirements.

Where deletion of your Personal Data requires termination of your account, your account may also be deactivated. Please note that permanently deleted accounts and associated information may not be recoverable.

Right to Object

Where applicable, you may object to the processing of your Personal Data. Depending on the circumstances, we may stop processing the relevant Personal Data while retaining it where we have a lawful basis or legal obligation to do so.

Right to Data Portability

In certain circumstances, you may request an export or copy of Personal Data that you have provided to us in a structured and commonly used format, where required by applicable law.

Right to Lodge a Complaint

Where applicable, you have the right to lodge a complaint regarding our processing of your Personal Data with the relevant data protection or supervisory authority.

If you wish to exercise any of the rights described above, please contact us by email at:

[email protected]

You may also contact us at the same address for questions concerning this Privacy Policy or our processing of Personal Data.

STORAGE OF PERSONAL DATA

We seek to retain Personal Data only for as long as reasonably necessary for the purposes for which it was collected or as otherwise required or permitted by applicable law.

We may retain information where necessary to:

• Resolve disputes.
• Enforce our agreements.
• Provide continued access to our Services.
• Establish, exercise, or defend legal rights.
• Comply with legal and regulatory requirements.
• Meet technical, security, and operational requirements.
• Prevent fraud or other unlawful activity.

Certain Personal Data and transaction-related information may need to be retained for a minimum period following the termination of a business relationship where required for KYC, AML, legal, regulatory, or other compliance purposes.

Where Personal Data is retained for these purposes, access will generally be restricted internally to individuals who require the information for legitimate business, legal, compliance, security, or operational purposes.

When Personal Data is no longer reasonably necessary for providing our Services, complying with applicable laws and regulations, protecting our legal rights, or operating our business, we will take reasonable steps to delete or otherwise dispose of the information, subject to applicable retention requirements.

CONTACT US

If you have any questions, concerns, requests, or complaints regarding this Privacy Policy or the way we process Personal Data, please contact:

Email: [email protected]