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Last updated: June 11, 2025

PRIVACY POLICY

1. CONTROL OVER YOUR DATA

This document explains the approach of Livin and its affiliated entities (“we”, “us”, “Livin”) to processing your personal data when using the Livin Platform. Depending on your region of residence and activity on the Platform, additional privacy rules may apply.

1.1. Role of the Platform
The terms “Livin”, “we”, “us”, and “our” in this document refer to the Livin Platform, which provides the technical infrastructure for listing and booking properties. We ensure the collection, transmission, and storage of user data but do not use personal data for our own purposes, except as explicitly stated in this Privacy Policy.

1.2. Payment Providers
Payments on the Platform are processed through third-party payment systems. The processing of payment data is carried out by these providers on their side according to their terms and security standards (e.g., PCI DSS). Livin does not store full payment details (e.g., card numbers and CVV codes) and only receives tokenized information necessary to confirm transactions and support users.

1.3. Identity Verification
If identity verification is required, the Platform may engage trusted verification partners. The materials you provide (e.g., document photo and selfie) are transmitted to the partner solely for automated authenticity checks. Livin does not store document copies or biometric data after verification is completed. The processing of such data is governed by the partner's privacy policy.

2. CATEGORIES OF COLLECTED DATA

2.1. Information for basic functionality
We receive your data when you use the Livin Platform. Without it, access to a number of services is not possible. The list includes:

2.1.1. Contact and profile information
First name, last name, phone number, mailing address, email, date of birth, avatar. The amount collected depends on the features you use.

2.1.2. Identification data
Upon request and in accordance with the law, we may request: a photo of a government-issued ID, passport, national ID card, taxpayer document, or driver’s license, along with date of birth, address, email, phone number, digital ID, and/or a selfie. This data is requested solely for identity verification. When a document is provided, we extract the necessary information from it.

2.1.3. Payment details
We do not collect or store full payment card or account data. All transactions are processed through secure payment providers that comply with international standards (e.g., PCI DSS). We may receive tokenized information such as card mask (e.g., last 4 digits), type of payment method, and aggregated transaction data (date, time, amount, transaction status) — solely for payment confirmation and user support.

2.2. Voluntarily provided information
You may share additional information with us, including:

2.2.1. Profile additions
Gender, preferred languages, city, biography, other details.

2.2.2. Third-party data
Payment details or contact information of another person, your fellow travelers or co-residents. By providing such data, you confirm your right to share it with Livin and that these persons are aware of this Privacy Policy.

2.2.3. Biometric data
Facial recognition data (with your consent, if required by law) obtained from your photos and documents during verification.

2.2.4. Communication data
Emails, calls, messages, SMS (if allowed on the Platform). May include recordings and transcripts (in accordance with the law), phone numbers, emails, time/date/duration, routing data, type and volume of communication.

2.2.5. User content
Photos, videos, and other content you share.

2.2.6. Support information
Call recordings (where permitted by law), chat data, and messages — for support, issue investigation, and service improvement.

2.2.7. Other information
Data from forms, account additions, survey responses, research participation, forum posts, promotions, imported/entered contacts, address/geolocation, company information, and reviews. This also includes medical data if you choose to share it.

2.3. Automatically collected data
When using the Platform, we automatically receive:

2.3.1. Geolocation
Exact/approximate location via IP, device GPS, or other data (depending on settings). May be collected even when the app is not actively in use if permission is granted.

2.3.2. Usage data
Search queries, bookings, additional services, login dates/times, pages or actions before/after using the Platform, links to external apps. Collection may occur without an account or login.

2.3.3. Device data
IP address, hardware/software information, device events, unique identifiers, crashes. Collection may occur without an account or login.

2.3.4. Cookies and similar technologies (regulated by a separate Policy).

2.4. Data from third parties
We may receive information from the following sources:

2.4.1. Third-party services
When linking your Livin account with another service (Google, Facebook, etc.) or logging in via them, you allow us to access your registration data, contact list, and profile (as per service settings). If a smart lock is connected, we may receive device logs and events.

2.4.2. Verification providers
With your consent (if required) and within the law, we may receive reports to assess reliability and safety using your full name and date of birth.

2.4.3. Corporate accounts
Organizations using Corporate products may provide data to manage accounts and send invitations.

2.4.4. Referrals and fellow travelers/co-residents
If you were invited to the Platform (e.g., as a fellow traveler/co-resident), the inviter may provide your data.

2.4.5. Complaints
If another user files a complaint against you, we may receive relevant information to review it.

2.4.6. Financial institutions
When paying from a bank account, we may receive certain data from the financial institution, such as account details.

2.4.7. Installment partners
If using installment plans, we may receive your payment schedule and performance from the provider.

2.4.8. Other sources
In accordance with the law, we may receive data from: (i) service providers, partners; (ii) users, organizations, or government bodies — for recommendations, demographics, fraud prevention, security, or data enrichment. This may include public information (e.g., social media), and data about your activity on or off the Platform. In some cases, medical information may be shared, including infectious disease data.

3. PURPOSES OF DATA USE

We use data in accordance with this Privacy Policy.

3.1. Providing the Livin Platform
For:
  • ensuring access to the Platform, processing and receiving payments;
  • facilitating interaction between users;
  • processing requests;
  • providing support;
  • sending messages, updates, security and account notifications;
  • determining country/state of residence based on account data and activity;
  • providing accommodation services.

3.2. Platform Development
For:
  • analytics, debugging, research;
  • improving products and services;
  • training customer support staff.

3.3. Personalization
For:
  • customizing the interface based on your activity, search/booking history, profile, and preferences;
  • adapting the user experience.

3.4. Protection of the Platform and Community
For:
  • combating discrimination;
  • detecting, preventing, and assessing fraud and security threats;
  • protecting the community from illegal activities (see Safety Rules);
  • verifying the data you provide (including identification data);
  • cross-checking data with databases (including background checks);
  • complying with laws, protecting users' and the public’s health;
  • resolving disputes (including informing other participants);
  • enforcing contracts with third parties;
  • eligibility checks for specific types of bookings (e.g., instant booking);
  • complying with legal requests, preventing harm, and protecting rights;
  • enforcing Terms of Service and other policies;
  • assessing your activity and third-party data.

3.5. Advertising and Marketing
For:
  • sending promotional and marketing materials;
  • displaying, personalizing, evaluating, and optimizing ads;
  • managing referral programs, rewards, surveys, contests;
  • analyzing preferences to send relevant content;
  • inviting to events.

3.6. Analyzing Your Messages
3.6.1. Purpose
We may analyze your messages on the Platform for security, support, and product improvement (e.g., detecting hidden contacts/links to combat fraud). According to the law, we check all images uploaded by users (in chats, profiles, listings, reviews) for illegal content (e.g., child exploitation) to identify violations and inform authorities.

3.6.2. Methods
We use automated tools. Manual review may be conducted for investigations or support.

3.6.3. No Commercial Use of Analysis Results
The results of checks and analysis are not sold.

3.7. Securing Payments
To process payments and ensure their security, we use third-party payment partners that comply with international standards (e.g., PCI DSS).
Payment partners may use the data shared with them only for:
  • processing and confirming payments;
  • fulfilling their obligations under contracts with users and us;
  • identity verification;
  • detecting and preventing fraud, money laundering, and other security threats;
  • conducting investigations and risk assessments;
  • complying with payment service regulations;
  • operating and improving payment infrastructure.

4. DATA SHARING

4.1. With your consent
We share data based on your permission or instruction (e.g., when connecting a third-party app, applying for an installment plan, or participating in partner promotions).

4.2. Information recipients
We may share data with:

4.2.1. Other users
To simplify booking/interactions:
Between Guest and Host: when requesting a booking or in case of a dispute, the following Guest data may be shared: profile, name, names of co-travelers/co-residents, cancellation history, reviews, age (if applicable), and other information necessary to resolve the issue. Once the booking is confirmed, the Guest receives the Host’s profile photo and phone number, and the Host receives the Guest’s profile, name, phone number, and listing address. These details may also be shared with co-travelers if required for the booking.

4.2.2. Host service providers
Hosts may share Guest data with third parties they engage to manage or provide services via Platform functions.

4.2.3. Management companies
We may share Host and Guest data (bookings, compliance) with property owners, HOAs, or building managers to support their programs.

4.2.4. Livin for Business partners
If a booking is made by a Guest on behalf of a company participating in the program, we share booking data with that company for contract execution.

4.2.5. Our service providers
We share personal data with affiliated and non-affiliated service providers (and their providers) to support our operations and help them comply with regulations. This includes those helping us: (i) verify identity/documents; (ii) check public databases; (iii) conduct background checks, investigate security incidents, assess risks; (iv) develop, maintain, debug products; (v) provide Livin Services via external platforms; (vi) offer support, marketing, and payment services; (vii) provide additional services you selected; (viii) handle similar requests; (ix) analyze messages (including child exploitation detection); (x) offer installment plans via lenders. These providers must protect your data and disclose it only as legally required.

4.2.6. Affiliates
We share data within our group of companies to integrate, promote, and improve the Platform.

5. INTEGRATIONS AND THIRD-PARTY SERVICES

5.1. Linking accounts
When linking your Livin account with a third-party service account:
  • some data from the linked account may appear in your public profile;
  • this data may be stored and processed for fraud prevention, security investigations, and risk assessment;
  • we may share booking data with travel and loyalty program partners;
  • the visibility of data from linked accounts is governed by your settings on the Livin Platform and the third-party service.

5.2. Third-party terms
The Platform may contain links to third-party services. Their use is subject to the privacy policies of those service providers.

6. CHANGE OF COUNTRY OF RESIDENCE

6.1. New Data Controller
When you change your country of residence, the Data Controller and/or Payment Operator is determined based on your new region from the moment of change.

6.2. Data transfer between Controllers
To provide services, personal data may be transferred between the Livin Platform and its trusted partners, including payment providers, verification services, and, if necessary, insurance companies. Such transfers occur when needed to process payments, verify identity, provide insurance, or perform other functions related to the Platform. Each partner processes data within their own responsibility and privacy policy. Data is transferred strictly in accordance with applicable law and only to the extent necessary.

6.3. User rights
Your rights may vary depending on your country of residence in accordance with local laws.

7. MANAGING YOUR DATA

You can view and update your data in your Account settings. You are responsible for its accuracy.

8. DATA RETENTION PERIODS

8.1. Retention criteria
We store data for the period necessary/permissible to achieve the purposes of collection and in accordance with current legislation. Criteria used to determine retention periods include:
  • duration of your relationship with Livin as Guest/Host and a post-relationship period during which we have a legitimate need to store the data;
  • presence of legal, tax, reporting, or audit obligations;
  • need to protect our legal positions or those of others.

8.2. Publicly shared information
Information you have shared with other users (e.g., reviews, posts) may remain on the Platform after your Account is deleted.

8.3. Backups
Backup data may not be deleted immediately due to the need to protect against data loss or corruption.

9. SECURITY MEASURES

We continuously implement and improve administrative, technical, and physical measures to protect your data from unauthorized access, loss, destruction, or alteration, although absolute security cannot be guaranteed.

10. POLICY CHANGES

We reserve the right to make changes to this Policy in accordance with the law. The updated version will be published with the date. For significant changes, we will notify you in the app or by email at least 30 days before they take effect. If you disagree with the updated Privacy Policy, you may delete your Account. If you do not delete your Account before the changes take effect and continue using the Livin Platform, you thereby confirm your acceptance of the updated Policy.

11. CONTACT INFORMATION

If you have questions or complaints related to this Privacy Policy or the processing of personal data while using the Livin Platform, you may contact us using the following details:

LLP “Birdhouse”
BIN: 220340038469
Legal address: Republic of Kazakhstan, Almaty, Baitursynov Street 141
Email: support@livin.kz
Phone: +7 (777) 747-17-39

If your inquiry concerns payment operations, please use the contact information provided in the Description of the payment procedure.

12. DEFINITIONS

If a term is not defined in this Privacy Policy, its definition corresponds to the one in the User Agreement.