Vizzle Privacy Policy

WHAT DOES THIS PRIVACY POLICY COVER?

Your privacy is extremely important to Vizzle. We are committed to protecting your Personal Data (as that term is defined further below). We want to be transparent with you about how we collect and use your Personal Data in making our website and mobile applications ("Platform") available to you and tell you about your privacy rights and how the law protects you.

This Privacy Policy aims to give you information on how "Vizzle" collects and processes your Personal Data through your use of this Platform.

By using the Platform, you agree to the collection, use and transfer of your Personal Data as set out in this Privacy Policy.

With that in mind, this Privacy Policy covers the following:

• WHO WE ARE AND HOW TO CONTACT US
• PERSONAL DATA WE COLLECT FROM YOU
• PERSONAL DATA WE COLLECT FROM OTHER SOURCES
• HOW WE USE YOUR PERSONAL DATA AND WHY
• WHO WE SHARE YOUR PERSONAL DATA WITH
• HOW WE KEEP YOUR PERSONAL DATA SECURE
• HOW LONG WE STORE YOUR PERSONAL DATA
• YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
• MARKETING COMMUNICATIONS
• OUR POLICY ON MINORS
• THIRD PARTY LINKS
• CHANGES TO THIS PRIVACY POLICY

We may revise this Privacy Policy from time to time, with or without notice to you. If that happens, the new version of this Privacy Policy will be made available on this page.

This Privacy Policy may be published in different languages. If that is the case and there are any inconsistencies between versions, the English language version will prevail.

WHO WE ARE AND HOW TO CONTACT US

We, Livera Infocomm Limited operates the Platform and is therefore the controller of your Personal Data (referred to as either "Vizzle", "we", "us" or "our" in this Privacy Policy). Our address is Livera Infocom Ltd, Near Lawex Legal Alias, Eranhippalam, Kozhikode, Kerala 673006, India

How to contact us

You can contact us by emailing: connect@liverauae.com

PERSONAL DATA WE COLLECT FROM YOU

The Personal Data we collect directly from you is outlined in the table below.

"Personal Data" is information about an individual from which that individual is either directly identified or can be identified. It does not include 'anonymised data' (which is information where the identity of an individual has been permanently removed). However, it does include 'pseudonymised data' (which is information which alone doesn't identify an individual but, when combined with additional information, could be used to identify an individual).

Aggregated data

We also collect, use and share 'aggregated data', such as statistical or demographic data for a number of purposes. Aggregated data may be derived from your Personal Data, but once in aggregated form it will no longer constitute Personal Data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Behavioural Data to calculate the percentage of users accessing a specific Platform feature. However, if we combine or connect aggregated data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

Special categories of personal data

We do not knowingly collect any 'special categories of personal data' about you (this includes, for example, details about your race or ethnicity, religious or philosophical beliefs, political opinions, information about your health, genetic and/or biometric data, and information about criminal offences and convictions).

We advise you not to share any of that data with us (for example, through our support chat function) or other users of the Platform (for example, through the user-to-user chat function). However, should you choose to share such data with us or other users of the Platform, you consent to us processing such data in accordance with this Privacy Policy.

What happens if you refuse to provide necessary Personal Data?

You do not have to provide any Personal Data to us. However, where we need to process your Personal Data either to grant you access to the Platform or to comply with applicable law, and you fail to provide that Personal Data when requested, we may not be able to provide you access to the Platform. For example, we need your email address in order to register your account on the Platform.

PERSONAL DATA WE COLLECT FROM OTHER SOURCES

In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are set out in the table below.

HOW WE USE YOUR PERSONAL DATA AND WHY

We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so (please refer to the 'Changes to this Privacy Policy' section further below).

What is our 'legal basis' for processing your Personal Data?

In respect of each of the purposes for which we use your Personal Data, applicable privacy laws require us to ensure that we have a 'legal basis' for that use. Most commonly, we will rely on one of the following legal bases:

• Contractual Necessity: Where we need to process your Personal Data to meet our contractual obligations to you (for example, to provide you access to the Platform).
• Compliance with Law: Where we need to process your Personal Data to comply with our legal or regulatory obligations.
• Consent: Where we have your consent to process your Personal Data for a specific purpose.

We have set out below, in a table format, the legal bases we rely on when processing your Personal Data.

WHO WE SHARE YOUR PERSONAL DATA WITH

The table below describes who we may share your Personal Data with and why we share it.

We require all recipients of your Personal Data to implement appropriate security measures to adequately protect it, consistent with our policies and any data security obligations applicable to us. We do not permit our third-party service providers who process your Personal Data on our behalf to use it for their own purposes, and only permit them to process your Personal Data for specified purposes in accordance with our instructions.

• Other users of the Platform: We need to share some of your Personal Data with other users when you wish to transact with them. By placing an advert or submitting a review/rating on our Platform, that information and any Personal Data associated with your account profile (including your username, profile picture and Vizzle Verified status) will be publicly accessible to, and may be copied and shared externally by, all other users of our Platform. Such information may also appear in third party search engine results. Please ensure that you are comfortable with such information being publicly available before submitting it on our Platform.
• Service providers: Our service providers provide us with a range of services necessary for the operation of the Platform (for example, IT, system administration services, or marketing services), and may have access to your Personal Data as a result.
• Our affiliates: Vizzle is part of the Livera Infocomm Limited. Our affiliated companies may require access to your Personal Data as they help us operate the Platform and manage user data.
• Professional advisers: Our lawyers, bankers, auditors, insurers and other advisers may require limited access to your Personal Data when they provide consultancy, banking, legal, insurance and accounting services to us.
• Public authorities: Public authorities may require us to disclose user data to them under certain circumstances, where required by law.
• Acquirer(s): We may share your Personal Data with third parties in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business. Where that is the case, we will ensure that any such recipient(s) continue to use your Personal Data in accordance with this Privacy Policy.

Data transfers

We may transfer your Personal Data to jurisdictions outside of the country in which you are located that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Privacy Policy. We will always ensure that any such cross-border transfers of your Personal Data comply with applicable requirements.

HOW WE KEEP YOUR PERSONAL DATA SECURE

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost or altered, or used or accessed in an unauthorised way.

We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such persons are subject to a contractual duty of confidentiality.

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to mitigate any impact to your privacy and to work with relevant regulators.

HOW LONG WE STORE YOUR PERSONAL DATA

We will only retain your Personal Data for as long as we reasonably need to use it for the purposes set out in this Privacy Policy, unless a longer retention period is required by applicable law (for example, for regulatory purposes).

Under some circumstances, we may anonymise your Personal Data so that it can no longer be associated with you. We may retain such anonymised data indefinitely.

Our data retention policies are reviewed at regular intervals and comply with all applicable requirements.

YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

Your rights

Under some circumstances, you may have certain rights in relation to your Personal Data. For example, you may have the right to:

• Request access to your Personal Data: This allows you to receive a copy of the Personal Data we hold about you, and to check that we are lawfully processing it.
• Request the correction of your Personal Data: This allows you to ask for any incomplete or inaccurate information we hold about you to be corrected.
• Request the erasure of your Personal Data: This allows you to ask us to delete or remove your Personal Data from our systems where there is no good reason for us to continue processing it.
• Object to the processing of your Personal Data: This allows you to object to our processing of your Personal Data for a specific purpose (for example, for marketing purposes).
• Request the transfer of your Personal Data: This allows you to request the transfer of your Personal Data in a structured, commonly-used, machine-readable format, either to you or to a third party designated by you.
• Withdraw your Consent: This right only exists where we are relying on your Consent to process your Personal Data. If you withdraw your Consent, we may not be able to provide you with access to the certain features of our Platform. We will advise you if this is the case at the time you withdraw your Consent.

Please note that not all of the rights listed above may be available to you, and some rights may only be exercisable in specific circumstances.

How to exercise your rights

If you want to exercise any of the rights described above, please contact us.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that your Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month of receipt. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.

Although we will typically not charge a fee for exercising your rights described above, we reserve the right to charge a reasonable fee in some circumstances (for example, if your request is unreasonable or if you submit an excessive number of requests).

Complaints

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us. We will reply to your complaint as soon as we can.

If you are unsatisfied with our response to any issue that you raise with us, you may have the right to submit a complaint to the data protection authority in your jurisdiction.

MARKETING COMMUNICATIONS

You can ask us to stop sending you marketing messages at any time by logging in to the Platform and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the "Unsubscribe" link included at the bottom of any marketing email you receive from us.

OUR POLICY ON MINORS

This Platform is not intended to be used by minors, and we do not actively monitor the age of our users.

However, if you become aware that a minor has been using the Platform in breach of this restriction, please contact us if you would like us to remove their Personal Data from our systems.

THIRD PARTY LINKS

This Platform may include links to third party websites and applications. Clicking on those links will take you off-Platform and may allow third parties to collect or share your Personal Data. We do not control these third-party websites and applications and are not responsible for their privacy practices. When you leave our Platform, we encourage you to read the privacy policy of every website and application you visit.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to update this Privacy Policy at any time, with or without notice to you.

Where that is the case, we will update this page to display the revised Privacy Policy and may also under certain circumstances notify you (for example, by email).

Any revisions to this Privacy Policy will be effective immediately once posted on this page.

DATA PRIVACY NOTICE FOR CANDIDATES OR JOB APPLICATIONS

Data Privacy Notice for Candidates or Job Applications can be found below.

TABLE OF CONTENTS

• Introduction
• Information we Process
• Legal basis of processing
• How is your personal information collected?
• How we will use your personal information
• Do we need your consent to process your personal data?
• If you fail to provide personal information
• Change of purpose
• Disclosure of personal information to other members of Livera Infocomm Limited
• Sharing your personal information with third parties
• Transfer of personal information to third countries
• Data security
• Data storage
• Data minimisation
• Your duty to inform us of changes
• Your rights in connection with personal information
• Right to Access Information, Object, Correction, Erasure, Restriction of Processing, Data Portability, Withdraw consent
• Complaints

1. INTRODUCTION

Livera Infocomm Limited and its affiliated entities (together referred to as "we", "us", "our" and "Vizzle Group") are committed to maintaining the highest standards in data privacy, confidentiality and information security. Vizzle Group is committed to protecting the privacy and security of your personal information.

This notice applies to candidates or job applicants only. We process your data in an appropriate and lawful manner, in accordance with the applicable laws and regulations to which Vizzle Group is subject, including the applicable Indian data protection laws Concerning Protection of Personal Data ("FDPL").

In accordance with these data protection laws, the Vizzle Group entity set to be your employer is a Data Controller. We will comply with local data protection laws in the jurisdictions we operate in. The personal information we hold about you must be: used lawfully, fairly and transparently; collected only for valid purposes; relevant and limited; accurate and kept up to date; kept only as long as necessary; kept securely.

2. INFORMATION WE PROCESS

The personal data we will collect, process, use or store in connection with your application to work with us will include: information you have provided in your application form (name, title, address, telephone number, personal email address, date of birth, gender, employment history, educational degrees, and qualifications); information set out in your CV and covering letter; any information you provide us during an interview; a copy of your passport, driver's license and/or national ID.

We may also collect 'special categories' of more sensitive personal information: original copies of your passport and/or national ID; information about criminal convictions or offences (e.g. police clearance certificate); any health-related data for the purposes of ensuring your health and safety in the workplace and assessing your fitness to work.

3. LEGAL BASIS OF PROCESSING

We collect personal information through the application and recruitment process, directly from you. We may also collect information from employment agencies, recruiters, former employers or colleagues, and from public sources or background checks.

We will use personal information we collect about you to: verify your skills, qualifications, and suitability for the role; carry out background or reference checks; communicate with you about the recruitment process; keep records relating to our hiring process; for health insurance checks, if applicable; comply with legal or regulatory requirements; keep you within our talent pool for any suitable upcoming roles.

We do not need your consent if we use your personal information prior to employment because we process your data based on the legal grounds listed above. In certain cases, it may be necessary for us to obtain your prior (explicit) consent. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

If you fail to provide certain information when requested (such as evidence of qualifications or work history), we may not be able to perform our recruitment obligations successfully or comply with our legal obligations.

4–7. DISCLOSURE, SHARING, TRANSFERS & DATA SECURITY

There may be instances where personnel of other members of the Vizzle Group get involved in the recruitment process and therefore your personal information will be shared with those affiliates. We may share your personal data with third-party due diligence/background verification report providers, and with government authorities (e.g. for work permit or visa purposes). Transfers of personal information outside your jurisdiction will be done in accordance with applicable data protection laws.

We have put in place appropriate security measures to prevent your personal information against unlawful or unauthorised processing, and against accidental loss or damage. All personal information is stored in a secure environment with physical and electronic data access controls. No method of transmission is 100% secure and absolute security cannot be guaranteed.

8–10. DATA STORAGE, MINIMISATION & YOUR DUTY TO INFORM

We retain your personal information until it has met its disclosed purpose. We retain it so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise fairly. If we enter into an employment agreement with you, we will provide you with our Privacy Policy for Employees.

Whenever possible, we anonymise the data we hold about you when it is no longer necessary to identify you. The personal information we hold about you must be accurate and current. Please keep us informed if your personal information changes during your recruitment process with us.

11. YOUR RIGHTS IN CONNECTION WITH PERSONAL INFORMATION

Where applicable, you may be entitled to exercise: Right to Access Information; Right to Object; Right to Correction; Right to Erasure; Right to Restriction of Processing; Right of Data Portability; Right to Withdraw Consent. We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

12. COMPLAINTS

We welcome any comments, complaints and queries in relation to data protection. You may contact your HR representative and we shall try our best to deal with any issue or concern you may have.