Privacy Policy 

Effective date: June 26,2025

1. About

Data Controller: ROACHES PROPERTY MANAGEMENT LTD, a company incorporated in the United Kingdom at 15 Cromwell Terrace LEEK-ST13 5JS

This Privacy Policy describes how ROACHES PROPERTY MANAGEMENT LTD ("We") collects, uses, discloses and protects your personal data when you use our mobile applications or any digital services ("Services").

This Privacy Policy is formulated in accordance with the following regulations and policies:

Ø Google Play policy: covers user specifications, distribution requirements, security guidelines, data protection and child safety guidelines.

Ø General Data Protection Regulation (GDPR) -EEA: aims to guarantee the legality of user data collection and processing in the European Economic Area.

Ø California Consumer Privacy Act (CCPA) -United States: Clarifies the scope of privacy rights and protections for California residents.

Ø Data Protection Act 2018 (DPA) -A complement to the UK GDPR, containing further specific restrictions, exemptions, and grounds for processing sensitive personal data on data processing activities.

These regulations form the core framework of our data processing practices to ensure full compliance with global privacy standards.

Please note: When you use [Livva], you have read, understood and agreed to all the terms of this Privacy Policy. If you do not agree with any part of this policy, please uninstall or stop installing the [Livva] application immediately.

2. Coverage and applicable conditions

This Privacy Policy applies to all aspects of data collection, processing and protection during your interaction with [Livva], whether you are using the features of the application, communicating with our support team via email, or interacting with other users. The entity responsible for processing your personal data is [ROACHES PROPERTY MANAGEMENT LTD].

Please note that this policy does not cover third-party services you may interact with while using our application. We will not sell, trade, or share your personal data with third parties. However, if you choose to use external services (such as payment providers or social media logins), their privacy policies will apply. We strongly recommend that you review their data processing practices before using their services.

This policy applies to the following situations:

Ø When you access, use or register for the App's services.

Ø When you voluntarily provide personal data in exchange for support, inquiries or feedback.

You reserve the right to retain certain information in the following circumstances:

Ø If there is no legal requirement to enforce it.

Ø If you don't want to share information with us.

Ø If you do not agree with us or our affiliated service providers to process data.

3. Core concept interpretation
To ensure the clarity of this Privacy Policy, we define the following terms:

Ø Personal Information: any data that directly or indirectly identifies an individual, including but not limited to name, contact information, personal information and any other personally identifiable information.

Ø Technical data: Information automatically collected as users interact with applications, such as device specifications, operating system details, and system diagnostics.

Ø Data used: Behavioral information generated by using the application, including session duration, functional interactions, and participation patterns.

Ø User data: any personal or non-personal information voluntarily shared or transmitted by the user when using the App service.

4. GDPR and CCPA

4.1 GDPR (General Data Protection Regulation)

Under the GDPR, Google must ensure that user data is collected and used in the EU based on explicit consent. If you are located in the European Economic Area (EEA), under the General Data Protection Regulation (GDPR), you have the following rights:

Ø Access: You can view the information we collect about your name, contact information, usage records, etc. at any time. We provide you with a clear list of information and query path.

Ø Right to correct: If you find any error or need to update the information, please contact us through customer service email (qwive.fiigur@gmail.com) for assistance. We will process it within 15 working days.

Ø Right to delete: You can apply for the deletion of specific information or submit an account cancellation application. We will delete the data as soon as possible within the scope permitted by laws and regulations and notify you (except for certain exceptions).

Ø Restriction of processing rights: You can close the contact book, location, camera and other permissions of [Livva] at any time. After closing, we will no longer collect the corresponding data, but it will not affect the use of the data during the authorization period.

Ø Data portability rights: You have the right to request that we export your registration information and usage data in common formats (such as CSV, JSON), which will be processed by us within 15 working days for you to facilitate your transfer to other services.

Ø Right to object: You can object to our processing of your personal data on legitimate grounds.

These rights apply to users in the EEA. If you wish to exercise your GDPR rights, please contact us via our customer support email and inform us of your request for rights.

4.2, CCPA (California Consumer Privacy Act)

If you are a California resident, under the California Consumer Privacy Act (CCPA), you have the following rights:

Ø Right to know: You have the right to request the categories of personal information about you that we collect and the purposes for which we use this information.

Ø Right to Delete: You have the right to request the deletion of your personal information. Please note that, under CCPA, we may not immediately delete your information if your deletion request involves legal obligations, security requirements, transaction records, platform operations, or backup data. We will inform you of the specific reasons and do our best to comply with your privacy request.

Ø Right not to sell personal Information: We will not sell your personal information, but you can ask us not to share certain data with third parties.

Ø Non-discrimination: We will not discriminate against you for exercising your CCPA rights.

These rights apply to users in California. If you wish to exercise your CCPA rights, please contact us through our customer support email and inform us of your request for rights.

5. Rules for the protection of minors' personal information
We place a high priority on protecting the privacy of minors, particularly those under 18 years old (or the legal age in their jurisdiction). We strictly adhere to relevant laws and regulations, such as COPPA (Children's Online Privacy Protection Act) and GDPR-K (EU General Data Protection Regulation-Children's Section), and take the following measures to protect children's personal information:

5.1. Restrictions on the collection of data on minors

Prohibited Actions: We do not provide services to minors under the age of 18 (or the legal age of majority in the local jurisdiction). We will not intentionally collect, store, or process any personal information of users under the age of 18, including but not limited to their names, addresses, emails, contact details, device identifiers, location data, or any other information that could identify them.

5.2. Illegal data processing

If we discover or receive notice confirming that a user under the age of 18 has provided personal information, we will immediately take the following measures (including but not limited to)

a. Delete the relevant data immediately and remove it completely from the server or database;

b. The user account is blocked to prevent it from continuing to access and use the application

c. Send account closure notice to users and clearly inform them that their data has been deleted;

d. The user is prohibited from registering again to avoid submitting any subsequent data.

5.3. Reporting mechanism for minors

Ø If you encounter suspected underage users when using the service, please keep relevant evidence (clear content or evidence) and report to us through customer service email or complaint channel of the application. After receiving your report, we will complete verification and processing within 72 hours and notify you of the result by email.

Ø If you are a parent or guardian and notice that the minor you care for is using our app, please contact us immediately via customer support email or complaint channels. We will complete user verification and take necessary actions within 24 hours, and provide the results via email. We also fully support guardians to delete or uninstall the app themselves.

As parents or legal guardians, you are responsible for supervising and managing your child's use of [Livva]. If a minor provides false information and claims to have reached the legal age, you will be fully responsible for any consequences arising from such false statements. We strongly recommend that parents and guardians educate their children about the importance of online safety and monitor their activities to ensure compliance with our policies and applicable laws.

6. Information collected by individuals
When you use our apps, for example, when you access and use our apps, install them on your device, or sign up for an account, we collect some information about you so that we can provide you with our services. For more details on this, see below.

6.1 Information we directly obtain

Ø Account information: When you register for this application or modify your personal Settings, we may collect data provided by you, such as user name, email address, phone number, profile picture, etc., and assign you a unique identifier account information.

Ø Payment information: We support and want you to process all paid services through Googleplay. We only collect transaction data from these platforms and do not collect or store sensitive information such as full payment card number.

Ø How we use it: We collect data from your use of the App, including messages, photos, videos, gifts and other user data. In addition, we process conversations with other users and content you share while using the App, which may be stored briefly to prevent violations.

Ø Communication information: When you contact our customer service or report a problem, we will collect your contact information, message content and other relevant data, such as your name or pseudonym, email address, IP address and any additional information you provide. This is mainly used to respond to and resolve the problems you have reported.

6.2. Information automatically collected by the system

Ø Device data: including device model, operating system version, IP address, unique device identifier, time zone, system language, etc.

Ø Usage data: includes data about how you use the app, such as chat duration, interaction frequency, content clicked, features used, etc.

Ø Log data: When you visit this application, we may automatically collect log data, including error reports, crash logs, etc. Such data is collected anonymously.

Ø Technical Data: Through third-party SDKs supported by the app store, such as firebase/tenjin/kochava/Facebook/Google Play billing, we automatically collect and analyze data at key points in our application services to optimize products or enhance user experience. We strongly recommend that you review the privacy policies and practices of these third-party SDKs. Below are links to the relevant SDK usage and privacy agreements.

6.3. Information collection by third parties

Ø Social media login: If you use a third-party account such as Google or Facebook to log in, we may obtain your basic account information from that platform (depending on the Settings of the platform).

Ø Payment service provider: When you make an in-app purchase, we may obtain transaction status information from the payment service provider.

6.4. Other information collection

Ø Information that requires your authorization: With your permission or authorization, we may collect your microphone, photo album, camera, geographical location and other information, mainly to meet the best experience of application services.

Ø Information from partners: If our ads appear on other websites or platforms, our partners may share data with us about the effectiveness of their ads.

7. How we use the information collected

Please rest assured that your information will not be shared or used by any third party. We may use your personal information for the following purposes:

Ø Account creation and login: We use your registration information (such as email, phone number) to create your account and allow you to log in securely.

Ø Customer support: Our customer service team may access your account information to help resolve any technical issues.

Ø Payment processing: If you use a paid service (for example, buying coins for video calls), we will use your payment information to securely process the transaction.

Ø What the app does: We may store your chat history and friends list to provide a seamless experience.

Ø Recommended matching: We may recommend users based on your interests, preferences and usage habits to enhance interaction.

Ø Display user profile: In order to help you find the right chat partner, we will show your basic information (such as nickname, avatar, gender) to other users and their information to you.

Ø Optimizing the communication experience: Based on your usage data (e.g., chat duration, interaction frequency), we will adjust the matching mechanism to improve the accuracy of recommendations for a better social experience.

Ø User behavior analysis: We analyze your usage habits (e.g., chat duration, match success rate) to optimize your experience.

Ø Test new features: Before launching new features, we may test them with a subset of users to evaluate their effectiveness and gather feedback.

Ø Performance optimization: We collect device information and network conditions to ensure that the App runs smoothly and reduces crashes or delays.

Ø Investigate misconduct: If a user reports an issue (such as harassment, fraud), we will analyze the relevant chat logs and transaction data to take appropriate action.

Ø Detect abnormal activity: We may regularly monitor abnormal activity (e.g., bulk creation of fake accounts, spam) and implement security measures.

Ø Crack down on violations: If content violates our community guidelines, we may warn users, restrict their accounts or take legal action.

Ø Regulatory compliance: We may process or store user data based on the user's location in accordance with relevant policies and laws.

Ø Assistance in law enforcement: If we receive a request from an enforcement agency at the user's location, we may provide relevant user data to assist in an investigation or law enforcement.

8. Data sharing and disclosure

We are committed to safeguarding your trust and personal information security. We will not provide, disclose, or share your personal information with any third party unless we have obtained your consent or if applicable laws permit such sharing. This policy outlines the third-party service providers we may engage to assist or enhance our services, as detailed below:

Please be aware that when you upload or post your personal information, posts, comments, videos, and other content, such content may be seen by anyone on the platform. [Livva] cannot guarantee that your content will not be discovered on other third-party platforms. You should exercise caution when disclosing personal information. We are not responsible for the information you choose to submit.

9. Information storage and risk control
Protecting your privacy and personal data security is our top priority. We prioritize data security and do everything we can to protect your data. Our main security measures include.

9.1 Data retention

Ø Principle of retention by data Controller: We will retain personal information in accordance with relevant policies, laws and regulations and the purpose of data authorization. The principle of minimum necessary period shall not exceed the time limit required to achieve the original processing purpose. When the purpose of data processing changes or terminates, the data deletion procedure shall be initiated immediately.

Ø User's voluntary submission of information: We will immediately perform data cleaning after processing the personal information submitted by you through feedback, consultation and other channels, and will not retain or back up in any form or transmit it to any third party.

Ø Account information management: You are voluntary, account deletion/disability triggers a 30-day countdown to deletion mechanism

Ø Instant messaging data: Chat log processing rules are by default subject to the session end burnout mechanism, unless temporarily stored for platform security purposes (e.g., suspected content review), but not for longer than the statutory investigation period.

9.2 Data encryption

We use encryption to store and transmit sensitive information.

9.3. Access restrictions

Only authorized personnel can access your personal information.

9.4. Data minimization

We only collect and store your information when necessary.

9.5 Data storage location

Your personal data may be stored on servers located in different parts of the world (including the United States, Europe and Asia).

9.6 Precautions

Security instructions for non-sensitive information: Email address, device IP address, and basic usage behavior data. We declare that we will use industry-standard protection measures to protect you from abnormal login behavior, but we cannot provide 100% security guarantee.

Definition of responsibility for third-party information sharing: When you choose to jump to a third party, interact with the interface, or share the behavior, we regard such behavior as the user exercising the data autonomy and exceeding the scope of security responsibility beyond our service boundary.

10. Your rights and choices
We respect your right to privacy. When using the product, we provide you with a variety of options to manage your personal information and exercise your rights.

10.1 Personal Information Access and Correction Policy

Ø Access: You can log in to your account at any time to view the personal information stored by us, including but not limited to your user name, email address, profile picture, chat history, etc.

Ø Correction: If your personal information changes and affects your normal use of the App, you can update your information in the App or submit a correction request through qwive.fiigur@gmail.com.

Ø Restrictions: Please note that in certain circumstances (such as those involving security or legal compliance requirements), we may not be able to provide full access. However, we will do everything possible to meet your request and provide a reasonable explanation.

10.2. Delete your personal information

Ø You have the right to request the deletion of your personal information, including but not limited to account data, chat records and payment information.

Ø In the Settings of the application, you can submit a "delete account" request. We will process your request and delete your personal data within 7 working days.

Ø In certain circumstances (e.g., legal compliance, fraud investigation, account settlement), we may need to retain certain information for a period of time. Once these reasons no longer apply, the data will be permanently deleted.

10.3 Revocation of authorization

a. Disable data access

You can manage specific permissions on the device or within the application to limit our access to certain data. The following paths are common and may vary slightly from device to device:

Ø Location access: If you do not want the App to access your location information, you can disable this permission through device Settings> Privacy> Location Services. This may affect location-based recommendations or matching functions.

Ø Notification permissions: You can disable push notifications in App Settings to avoid receiving updates, message alerts, or marketing notifications.

Ø Microphone and Camera: If you do not want the application to access your microphone or camera (for example, for video chat), you can disable the permission in device Settings → Privacy → Camera/Microphone. This may affect the video call function.

b. Cancel subscription information
If you do not want to receive promotions, recommendations, or other marketing messages, you can unsubscribe by following these steps:

Ø Email: Click the unsubscribe link at the bottom of the marketing email to stop receiving marketing emails.

Ø App notification: Go to App Settings> Notification Preferences to disable promotional notifications while retaining necessary service notifications (such as payment reminders, account security notifications).

c. Request to stop specific data processing
You can ask us to stop processing your specific data, including:

Ø Matching recommendations: If you do not want personalized matching based on your profile, preferences, or interaction data, you can disable this feature in "App Settings"> "Privacy".

Ø Behavior analysis: We may analyze your usage habits to optimize the product experience. If you do not want the App to analyze your usage behavior (e.g., access history, usage frequency), you can limit data analysis in the privacy Settings.

Ø Third party data sharing: While we do not sell your personal information, if you want to limit the sharing of data with certain third parties (such as advertising partners), you can manage it in Data Sharing → Privacy Settings or contact customer support directly.

d、 special explanation

Ø We will process your request as soon as possible and provide feedback via email within 7 days.

Ø For data that cannot be deleted immediately (e.g., archived data for legal compliance or fraud investigation), we will provide a reasonable explanation within 7 days.

Ø If you have any questions about your privacy, please contact us through customer support.

11. Policy change and synchronization

Ø Unless required by Google Play policies, laws and regulations, new features or business and technical changes, this policy will not be updated at will.

Ø If there is an update, we will notify you in a variety of ways, including but not limited to in-app notifications, email and announcements.

Ø Continuing to use the application after receiving an update notification means that you agree to the new policy. If you do not agree with the new policy, you can adjust data processing permissions in your privacy Settings, contact customer support for other solutions, or disable and delete your account or application.

12. Contact us

If you have any questions about our Privacy Policy or need to exercise your rights related to personal Information, please contact us as follows:
Official Email：qwive.fiigur@gmail.com
We promise: [Livva] always takes your privacy protection as our core responsibility, and every feedback from you is an important basis for us to optimize. Thank you for choosing us, let's protect information security together.