Travel Members – Privacy Policy

1. Purpose

This Privacy Policy explains how LiveNow Affiliate Software LTD ("LN") collects, processes, shares, and protects the personal data of individuals who purchase the Annual Travel Pass and access the Travel Engine platform (https://travel.livenow.com.cy) ("Travel Members").

2. Data Controller and Third-Party Licensing

2.1. LN is the data controller for all data collected during the purchase and account setup of the Annual Travel Pass.

2.2. Once access is granted, relevant data is shared with the Travel Engine provider ("Travel Partner"), who becomes a joint or separate controller for in-platform processing.

2.3. The Travel Partner is solely responsible for in-platform data, transactional records, and travel booking support.

3. Data Collected

We may collect and process the following personal data: - Full Name - Email Address - Phone Number - Country of Residence - Language - IP Address and Device Information - Purchase Date and Status - Travel Preferences (voluntary)

4. Purpose of Processing

Your data is processed for the following purposes: - To process and activate the Annual Travel Pass

- To provision access to the Travel Engine

- To communicate support information and updates via email, SMS, or in-app notifications

- To fulfill legal, regulatory, and tax obligations

- To monitor and prevent abuse, fraud, or misuse of the platform

5. Data Sharing

5.1. LN shares necessary personal data with the Travel Partner to enable the creation of your Travel Engine account.

5.2. Support emails, SMS, and alerts may be sent by the Travel Partner.

5.3. Your data will not be sold or shared with any unrelated third parties without consent, unless legally required.

6. Data Storage & Retention

6.1. Data is stored securely on servers within the European Union (EU), hosted via Microsoft Azure.

6.2. If a Travel Member requests account deletion and no bookings have been made, the record may be deleted immediately.

6.3. If bookings exist, the record will be retained for 365 days after deactivation before permanent deletion.

7. Data Subject Rights

You have the right to: - Access your data - Request rectification or deletion - Restrict or object to processing - Lodge a complaint with the Office of the Commissioner for Personal Data Protection in Cyprus

Requests can be made via email to: [email protected]

8. Security Measures

LN and the Travel Partner employ appropriate technical and organizational measures to protect your data against unauthorized access, disclosure, alteration, and destruction.

9. Updates to this Policy

This Privacy Policy may be updated at any time without prior notice. Please check regularly for changes. Continued use of the Travel Engine constitutes acceptance of the latest version.

Data Controller Contact:

LiveNow Affiliate Software LTD

Email: [email protected]

Phone: +357 7008 8044