I. Introduction

When you use Liesl, you entrust us with your personal data. We are committed to maintaining that trust. Therefore, we would first like to help you understand our data protection practices.

In this Privacy Policy, we describe which personal data (“data”) we collect, how it is used and shared, and what options you have with regard to this data.

II. Overview

A. Scope

This notice applies to users worldwide of Liesl apps, Liesl websites, and other services provided by Liesl (“Liesl Services”).

This Privacy Policy describes how Liesl and its affiliated companies collect and use data. This Privacy Policy applies to all users of Liesl Services worldwide, unless they use a service for which a separate privacy policy applies.

All persons whose data we collect in connection with the use of Liesl Services are referred to in this Privacy Policy as “user” or “users.”

Our data protection practices are subject to the applicable laws in the places where we operate. This means that we only implement the measures described in this Privacy Policy in the respective countries or regions if this is permitted under local law.

Please also note the following:

Users can contact us here if they have questions regarding our practices in a particular country or region.

III. Data Collection and Use

A. Data We Collect

Liesl collects the following data:

• provided to Liesl by users

• generated during use of our services

• from other sources.

Here you will find a summary of the data we collect and how we use it.

Liesl collects the following data from these sources:

1. Data provided by users. This includes:

Account information: We collect data when users create or update their Liesl accounts or place orders using guest checkout payment features. This includes first and last name, email address, telephone number, login name and password, address, profile picture, payment or bank details (including related payment verification information), user settings (including accessibility settings), loyalty program information for Liesl partners, information on Liesl referral programs, insurance information, emergency contact information, and evidence of health or suitability for providing services via the Liesl apps.

Reliability check information: This includes information submitted during the application process as a qualified caregiver, such as a résumé, debt enforcement register extract or criminal record extract, driver’s license, previous addresses, and work permits.

Documents and photos for identity verification: This includes government-issued identification documents such as driver’s licenses or passports (which may contain ID photos and numbers, date of birth, and gender) and photos submitted by users such as selfies and profile pictures.

Demographic data: We collect demographic data such as date of birth/age, gender, or profession if this is required to activate certain features or enable access to age-restricted products or services. For example, we collect users’ date of birth or age. We also collect or infer gender information (using first names) in order to enable female or non-binary users to indicate their preference for providing or receiving services for/from female or non-binary users, as well as for marketing and advertising purposes. We also collect demographic data such as age group and household composition as part of user surveys.

User content: We collect data (including chat logs and call recordings) when users contact Liesl customer support, provide ratings or feedback for other users, use features that allow users to upload content or submit recordings (including in-app audio or video recordings or dashboard camera recordings), or otherwise contact Liesl.

2. Data generated during use of our services. This includes:

Location data (from caregivers): We collect location data from caregivers’ mobile devices when the Liesl app is running in the foreground (app open and on screen) or in the background (app open but not on screen).

Location data (from holders): We collect precise and/or approximate location information from holders’ mobile devices, provided they allow this via their device settings.

Liesl collects this data from the start until completion of the care service and every time the app is running in the foreground (app open and on screen). See “Choice and Transparency” below to learn how holders can enable precise location data collection.

In addition, precise location data collected from the caregiver during the provision of services is linked to the holder’s account, even if the holder has not enabled the collection of precise location data on their device. This data is used for purposes such as customer support, fraud detection, insurance matters, as well as legal disputes and the creation of receipts.

Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided, order details (such as date and time, requested pickup and delivery addresses, distance traveled, and ordered items or other delivery items), and payment information (such as name, charged amount, and payment method). We also link a user’s name with the name of all persons who use their promotional code.

This also includes information provided by users, such as details about pets’ allergies.

Usage data: We collect data on how users interact with our services. This includes date and time of access, app functions or pages viewed, browser type, app crashes, and other system activity.

Device data: We collect data about the devices used to access our services. This includes hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, and data on device motion and mobile network.

Communication data: We collect data relating to communication between users that is enabled through Liesl apps. This includes the type of communication (phone call, text message, or in-app message), date/time, and content (including recordings of phone calls, but only if users are informed in advance).

Chat moderation and abuse detection: Chat messages may be reviewed on a random basis or automatically in order to detect abuse, violations of the Terms and Conditions (including attempts to circumvent the platform), or security risks, and to ensure compliance with our rules. Processing is carried out on the basis of our legitimate interest (Art. 6(1)(f) GDPR / Art. 31 Swiss FADP) in ensuring the safety of the platform and its users, preventing fraud, and ensuring compliance with our contractual terms. Access to chat data is limited to authorized employees. Chat content is stored only as long as necessary for the aforementioned purposes, generally until the user account is deleted or a matter has been conclusively resolved. Where statutory retention obligations or ongoing proceedings require longer storage, the data is retained until those periods expire.

3. Data from other sources. This includes:

Users participating in our referral programs. For example, if one user refers another person, we receive the referred person’s data from that user.

Liesl account holders who request services for or on behalf of other users (such as friends or family members) or who allow other users to request or receive services through their business accounts (such as enterprise customers).

Users or other third parties who provide information in connection with claims or disputes.

Liesl business partners through whom users create or access their Liesl account, such as payment service providers, social media services, or apps or websites that use Liesl’s API or whose API Liesl uses.

Liesl business partners in connection with debit or credit cards issued by a financial institution in partnership with Liesl, to the extent stated in the card terms and conditions.

Service providers who help us verify users’ identity, background information, and fitness for work, detect fraud, and screen users in connection with sanctions, anti-money laundering, or know-your-customer requirements.

Providers of insurance or financial services for dog sitters and/or dog drivers.

Partner transportation companies (for dog sitters or dog drivers who use our services through an account associated with such a company).

Publicly available sources.

Marketing partners and service providers, including banks in connection with cash-back programs, and data brokers.

Law enforcement officers, health authorities, and other government authorities.

B. How We Use Data

Liesl uses data to enable reliable and convenient pet care services as well as other products and services. We also use data:

• to promote the safety of our users and services

• for customer support

• for research and development

• to enable communication between users

• for marketing and advertising

• to send non-marketing communications to users

• in connection with legal proceedings

Here you will find a summary of the data we collect and how we use it.

Liesl uses the collected data as follows:

1. To provide our services.

Liesl uses data to provide, personalize, maintain, and improve its services.

This includes using data for the following purposes:

Creating/updating accounts

Enabling transport, delivery, and other services/functions, such as:

• using location data to navigate pet pickups and arrivals, calculate estimated time of arrival, and track the progress of trips or deliveries

• matching available caregivers with holders requesting services, including based on personal data such as location and proximity to other users, and user settings/preferences (such as preferred destinations), and non-personal data such as the requested vehicle type

• enabling accessibility features

• enabling features involving account linking, including linking with third-party rewards programs

• facilitating and optimizing the booking, pickup, and drop-off of pets

• calculating prices, including by using location data and trip or order details (e.g. requested pickup and arrival addresses). We may also take into account non-personal data or factors, including date and time, estimated distance and duration, minimum base prices, tolls, taxes and fees, as well as dynamic pet care price adjustments

• processing payments and enabling payment products

• personalizing user accounts. For example, we display personalized recommendations based on previous orders and pickup and delivery locations

• enabling insurance, billing, or financing solutions

• providing updates on orders and deliveries, generating receipts, and informing users about changes to our Terms and Conditions, services, or policies

• carrying out the operations required to maintain our services, including fixing software bugs and operational issues

Liesl carries out the above activities on the basis that they are necessary for the performance of the terms of our agreements with users, are agreed with users, or are necessary for the legitimate interests of Liesl and its users.

2. Fraud prevention and safety.

We use data to ensure the safety and integrity of our services and users. This includes:

• verifying users’ accounts, identity, or compliance with safety requirements

For example, we verify the reliability of qualified caregivers (including criminal records, where legally required or permitted) in order to verify their identity and eligibility to carry out transportation or deliveries.

If necessary, we may also verify holders’ identity using names, date of birth, email addresses, telephone numbers, payment information, and third-party wallets in order to prevent fraudulent accounts from using our services.

We also require verification of users’ identity and/or age. We process and compare user profile photos, official ID photos and numbers, or other photos submitted by users in order to perform this verification, in some regions also through the use of facial recognition technology. We also use such technologies to prevent fraudulent use of identification photos or to prevent users from creating multiple accounts.

We also use facial recognition technologies to prevent fraudulent use of Liesl accounts by persons other than the account holder. This takes place through Liesl’s real-time ID verification, in which caregivers must regularly take a selfie before they can go online, and this is compared with their profile photo. We also use this feature to verify changes to bank account information and to facilitate restoration of account access.

• using customer service information (including reports of safety incidents), device data, transaction and usage data to identify potentially unsafe caregivers. This may result in caregivers receiving messages prompting them to handle pets more safely and/or their account being deactivated after human review

• using account, device, location, usage, transaction, mobile carrier, and other data, including communication between users and metadata, to prevent, detect, and combat fraud, including by guest users

• using reported incidents, user ratings, and other feedback to promote safe use of the Liesl app and compliance with our Terms and Conditions, and as grounds for deactivating users with low ratings

• using location, telephone number, username, vehicle details, and other relevant information to provide live support from safety experts

The fraud prevention and unsafe pet care prevention and detection activities described above may be considered profiling under applicable law and may lead to user deactivation (generally only after human review). Information on how you can object to the above activities can be found below in the section “Choices and Transparency.”

Liesl carries out the above activities on the basis that they are necessary to perform the terms of our agreements with users and/or to safeguard the legitimate safety interests of Liesl, our users, and the public.

3. Customer support.

We use the information collected (including call recordings, chat logs, audio recordings in apps, and video material from dashcams) to provide customer support, including investigating and handling user concerns and monitoring and improving our customer support responses and processes.

Liesl carries out the above activities on the basis that they are necessary for the performance of the terms of our agreements with users or for Liesl’s legitimate interest in monitoring and improving its customer service performance.

4. Research and development.

We use data for analytics, machine learning, product development, research, and testing. This helps us make our services more pleasant and user-friendly, improve the safety of our services, and develop new services and features.

Liesl carries out the above activities on the basis that they are necessary for Liesl’s legitimate interests in improving and developing new services and functions.

5. Enabling communication between users.

For example, a caregiver may send a text message or call a holder to confirm the pickup location; a holder may contact a caregiver to recover a lost item.

Liesl carries out the above activities on the basis that they are necessary for the performance of the terms of our agreements with users.

6. Marketing and advertising.

Liesl uses data (except data from guest users) to market its services and those of Liesl partners.

In particular, we use account, approximate location, device, and usage data, the preferred language, and order history to provide ads and marketing communications personalized based on users’ observed or inferred location, interests, and characteristics (including inferred gender).

This includes using this data for the following purposes:

• sending emails, text messages, push notifications, and in-app messages or other communications for marketing or advertising purposes relating to Liesl’s products, services, features, offers, promotions, sweepstakes, news, and events. For example, we may send push notifications suggesting a user’s preferred destinations or merchants, or in-app messages offering discounts or promotions for products or merchants similar to those previously ordered by the user

• displaying personalized advertisements in third-party apps or websites

• displaying third-party advertisements in Liesl apps or in connection with our services. For example, we display ads for merchants available via Liesl apps. These ads (labeled “Sponsored Ads” in Liesl apps) contain recommendations based on the user’s location and order history

• displaying ads for third-party products not available in Liesl apps. These ads may contain links to third-party apps or websites. Users should review those third parties’ privacy policies for information about their collection and use of data when visiting such apps or websites

• displaying personalized ads based on data about users’ current care requests, including the time of the request and the requested services

• measuring the effectiveness of Liesl ads and third-party ads displayed in Liesl apps or in connection with our services

Liesl carries out the above activities on the basis that they are necessary for Liesl’s legitimate interests in informing users about services and features offered by Liesl or its partners. In the sections “Choices and Transparency” and “Marketing and Advertising Choices,” you will find information about users’ choices regarding Liesl’s use of their data for marketing and advertising.

7. Non-marketing communications.

Liesl may use data to send surveys and other communications that are not for the purpose of marketing Liesl’s or its partners’ services or products. We may also send users communications relating to elections, voting, referendums, and other political processes related to our services.

Liesl carries out the above activities on the basis that they are necessary to fulfill our Terms of Use or other agreements with users, or to safeguard the legitimate interests of Liesl and its users by informing users about events that may affect their use of Liesl Services.

8. Legal proceedings and requirements.

We use personal data to investigate or handle claims or disputes relating to the use of Liesl Services, to comply with the requirements of applicable laws, regulations, operating licenses or agreements, or insurance policies, or in accordance with legal proceedings or government requests, including requests from law enforcement authorities.

Liesl carries out the above activities on the basis that they are necessary for Liesl’s legitimate interests in investigating and responding to claims and disputes relating to the use of Liesl’s services and functions and/or for compliance with applicable legal requirements.

9. Profiling and automated decisions.

Liesl uses profiling to improve its services, provide personalized advertising, and identify safety risks. Profiling is carried out on the basis of Liesl’s legitimate interests, provided this is compatible with the rights and expectations of users. Users have the right to object to automated processing that has legal or similarly significant effects, or to request human intervention.

10. Referral program.

Liesl stores and processes data in order to maintain a referral program. This includes, in particular, assigning referral links and codes, verifying whether registration or a first paid booking has taken place, calculating and granting rewards, and taking measures to detect and prevent abuse (e.g. fake accounts or self-referrals). Liesl carries out these activities because they are necessary for the performance of the terms of our agreements with users and to safeguard Liesl’s legitimate interests in a functioning and abuse-free referral program.

Exclusively lawful use

Liesl processes and uses personal data only where this is based on a lawful basis under applicable data protection laws. This includes in particular:

• the performance of a contract or pre-contractual measures,

• the safeguarding of legitimate interests of Liesl or third parties,

• the consent of the data subject, in particular in the case of processing sensitive data, and

• compliance with legal obligations.

Liesl ensures that the data collected is limited to what is necessary and is used only for the purposes described.

C. Cookies and Third-Party Technologies

Liesl and its partners use cookies and other identification technologies in our apps, websites, emails, and online advertisements for the purposes described in this Privacy Policy and Liesl’s Cookie Policy.

Cookies are small text files stored by websites, apps, online media, and advertisements on browsers or devices. Liesl uses cookies and similar technologies for purposes including:

• authenticating users

• storing user preferences and settings

• determining the popularity of content

• measuring and evaluating the effectiveness of advertising campaigns

• analyzing page views and trends and developing a general understanding of the online behavior and interests of people who interact with our services

We may also allow others to provide us with audience measurement and analytics services, serve advertisements on our behalf across the internet or for other companies’ products and services in our apps, and track and report on the performance of such advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the device visitors use to visit our website, and also when they visit other websites and services.

For more information on the use of cookies and the other technologies described in this section, please see our Cookie Policy.

D. Links

Our website or app contains links to third-party sites. We are not responsible for the content and data protection measures on external websites that you can access through these links. Please inform yourself about data protection directly on the respective websites.

E. Sharing and Disclosure of Data

Some of Liesl’s services and functions require that we share data with other users, or do so at the request or with the consent of a user. We may also share such data with our affiliated companies, subsidiaries, and partners where necessary for legal reasons or in connection with claims or disputes.

Liesl may share data as follows:

1. With other users

This includes sharing the following data:

First name, ratings, and the pet’s pickup and/or destination location.

As part of the Liesl referral program, we share data of referred users, such as the number of services, with the referring user insofar as this is necessary to determine the referral reward.

2. At the request of or with the consent of users

This includes sharing data with:

Liesl business partners. For example, if a user orders a service through a partnership or promotional offer provided by a third party, Liesl may share certain data with those third parties. This may include other services, platforms, apps, or websites integrating our API; suppliers or services; those with an API or service we integrate; merchants or other Liesl business partners and their users in connection with promotions, contests, or special services.

Emergency services. We offer features that allow users to share their data with police, fire, and emergency medical services in an emergency or after certain incidents. For more information, see “Choices and Transparency” and “Transmission of your data in an emergency” below.

Insurance companies. If a user has reported or submitted an insurance claim relating to Liesl’s services to an insurance company, Liesl shares certain data with that insurance company in order to adjust or process the user’s insurance claim.

Merchants. If a recipient of an order adds a merchant loyalty membership number to their user account, Liesl shares their loyalty membership and order details with the relevant merchant when they place an order. Order recipients may also choose to share their contact and order data with a specific merchant in order to receive marketing communications from that merchant.

The public. Questions or comments submitted by users through public forums such as Liesl’s blogs or social media pages may be viewable by the public. This includes any data contained in the submitted questions or comments.

3. With Liesl subsidiaries and affiliated companies

We share data with our subsidiaries and affiliated companies that support us in providing services or process data on our behalf.

4. With Liesl service providers and business partners

This includes the third parties or categories of third parties listed below. Where a third party is identified, you will find information in the linked privacy notices about the collection and use of personal data.

• payment processors and intermediaries

• background check, identity verification, and risk solution providers

• cloud storage providers

• customer support platforms and service providers

• Google, in connection with the use of Google Maps in Liesl apps

• social media companies, including Facebook and TikTok, in connection with Liesl’s use of their tools in Liesl apps and websites

• marketing partners and marketing platform providers, including social media advertising services, advertising networks, external data providers, and other service providers, to reach or better understand our users and measure advertising effectiveness

This includes advertising intermediaries that enable Liesl to display personalized ads for third-party products shown in Liesl apps and measure their effectiveness. We share data—including advertising or device identifiers, hashed email addresses, approximate location, current usage or order information, and ad interaction data—with these intermediaries to enable their services and for other purposes stated in their privacy notices. Users can disable ad personalization in the Liesl app.

• research partners, including those conducting surveys or research projects together with Liesl or on its behalf

• service providers helping Liesl improve the safety of Liesl apps and services

• service providers who provide us with artificial intelligence and machine learning tools and services

• auditors, consultants, lawyers, and other professional service providers

• insurance and financing partners

• insurance companies, in connection with insurance claims raised or reported by a user in relation to Liesl’s services, and for the purpose of adjusting or processing the insurance claim

5. For legal reasons or in the event of a dispute

Liesl may share users’ personal data if, in our view, this is required under applicable law, regulations, operating licenses or agreements, legal proceedings, government requests, or insurance policies, or if disclosure is appropriate because of safety or other concerns.

This includes sharing data with law enforcement officers, representatives of health authorities, or other government representatives, insurance companies, or other third parties where necessary to enforce our Terms of Use, user agreements, or other policies; to protect the rights or property of Liesl, or the rights, safety, or property of others; or where claims or disputes arise in connection with the use of our services. In disputes over the use of another person’s credit card, we may be legally required to share user data with the relevant credit card holder, including information about the use of a service or an order.

This also includes sharing data with third parties in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or part of our business by another company.

6. With consent

Liesl may also share a user’s data in a manner other than as described in this Privacy Policy if we inform the user of the sharing and the user consents to it.

F. Storage and Deletion of Data

Liesl stores user data for as long as necessary for the purposes described above. Users may request deletion of their account through the Liesl apps and websites.

This depends on the type of data, the category of users to whom the data relates, the purposes for which we collected the data, and whether the data must be retained after a request to delete your account for the purposes described below.

For example, we retain data:

• for the duration of user accounts where such data is necessary to provide our services, e.g. account data

• for 10 years where this is necessary to comply with tax regulations

• for specific periods required for safety or fraud prevention purposes. For example, we retain incomplete caregiver applications for one year and rejected caregiver applications for seven years

Users may request deletion of their account via the “Settings” > “Privacy” menu in the Liesl app or through the Liesl website.

Following an account deletion request, we delete the user’s account and data where this is required for reasons of safety, fraud prevention, or legal compliance, or due to issues related to the user’s account (e.g. an outstanding balance or an unresolved claim or dispute). For caregivers, this generally means that we retain certain of their data for as long as necessary for actual or potential tax, litigation, or insurance claims.

IV. Choices and Transparency

Among other things, Liesl enables users to access and review the data collected by Liesl through the following options:

• privacy settings

• device permissions

• rating pages in the apps

• marketing and advertising choices

Liesl also enables users to request access to or copies of their data, make changes or updates to their accounts, request deletion of their accounts, or request that Liesl restrict the processing of their data.

1. Privacy settings

Holders can set or update their preferences regarding the collection and sharing of location data, the sharing of emergency data, and notifications in the Liesl Privacy Center, accessible via the “Privacy” menu in the Liesl apps.

Collection of location data
Holders can enable or disable Liesl’s collection of location data in their mobile device settings in the location sharing menu in the Privacy Center in the Liesl apps.

Gender identity
Holders can update their gender information via the “Gender Identity” menu, accessible in the “Display and Data” menu within the Privacy Center.

Notifications: Credits and News
Users can allow Liesl to send them push notifications about credits and news from Liesl. Users can specify here whether they wish to receive push notifications.

Third-party app access
Users can authorize third-party applications to access their Liesl account data in order to enable additional functions. Users can review/revoke access by third-party applications here or via the Liesl Privacy Center.

For certain data processing activities, in particular the processing of sensitive data such as biometric data (e.g. facial recognition data), or the personalization of advertising based on user profiles, Liesl obtains the users’ explicit and informed consent. This consent may be withdrawn at any time via the privacy settings in the Liesl app, without affecting the lawfulness of processing carried out before the withdrawal.

2. Device access permissions

Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the permission of the device owner. Permission is granted differently depending on the platform. Users should review the available settings on their devices or contact their provider.

3. Rating pages in the apps

After each care service, holders can rate caregivers from 1 to 5 stars. The average of these ratings is linked to the user’s account and shown to other users when they provide services for or receive services from them. For example, holder ratings are shown to caregivers from whom a service is ordered.

4. Marketing and advertising choices

Liesl provides users with the following options regarding the use of their data for marketing and advertising purposes:

Personalized marketing communications from Liesl: Users can choose here whether Liesl may use their data to send personalized communications (such as emails, push notifications, and in-app messages) about Liesl products and services. Users can also choose here whether they wish to receive marketing emails or push notifications from Liesl.

Data sharing and tracking: Users can choose here whether Liesl may share their data with third parties or collect data about their visits and activities in third-party apps or on third-party websites for personalized advertising.

Personalized ads: Users can choose whether Liesl may use their order or search history to personalize the advertising they see on Liesl.

Cookies and related technologies: For more information on how you can control Liesl’s use of cookies and related technologies, including for the display of personalized advertising, please see our Cookie Notice.

5. User data requests

Liesl offers users various ways to learn more about how we handle their data, ask questions about it, provide comments, and review the data. In addition to the methods listed below, users can also submit data requests here through our privacy request form.

Data access and data portability: Depending on where they are located, users may have the right to “access” their data (i.e. to receive information about the data Liesl has collected about them) and to “portability” of their data (i.e. to receive a copy of that data). Regardless of location, Liesl offers several options for viewing and obtaining copies of the data Liesl has collected about them.

Users can access data, including their profile and order history, through the Liesl apps or the Liesl website.

Using our Explore Your Data feature, users can view an online summary of certain information about their account, such as number of orders, ratings, rewards status, and the number of days they have been a Liesl user.

Changing or updating data: Users can change the name, phone number, email address, payment method, and profile photo stored in their account through the “Settings” menu in the Liesl app or the driver portal.

Deleting data: Users can request deletion of their account through the Liesl Privacy Center.

Objections, restrictions, and complaints: Users may request that we no longer use all or part of their data, or that we restrict the use of their data. This also includes objection to the use of data based on Liesl’s legitimate interests. Liesl may continue to use this data after such an objection or request to the extent required or permitted by law.

In addition, depending on their location, users have the right to lodge a complaint regarding Liesl’s processing of their data with the data protection authority in their country. For example, users in the EU may send such requests to the data protection authority in the country in which they live.

Users have the right to lodge complaints with the data protection supervisory authority in Switzerland. The competent authority is the Federal Data Protection and Information Commissioner (FDPIC). Contact information can be found at: https://www.edoeb.admin.ch.

V. Legal Information

A. Data Controllers and Data Protection Officer

Liesl is the controller for the data processed in connection with the worldwide use of Liesl services, unless Liesl is jointly responsible for the processing together with other Liesl-affiliated companies.

Liesl is responsible for the data processing carried out in connection with Liesl services worldwide.

For inquiries related to data protection and the processing of personal data, users may contact the following contact point in Switzerland:

Data Protection Officer of Liesl
tobi@liesl.ch
+41 41 769 73 09
Liesl AG, Ruessenstrasse 6, 6340 Baar, Switzerland

B. Legal Framework for Data Transfers

Liesl operates globally and processes user data worldwide. We comply with the applicable legal frameworks relating to data transfers.

Liesl operates globally and processes user data worldwide. This may result in your personal data being processed in countries such as the United States, whose data protection laws may differ from those of your country of residence.

This includes processing your data on Liesl’s servers in the United States and globally transferring or enabling access to your data in order to:

• provide services to you wherever you request them

• enable you to access your information such as trip/order history wherever you request it

• grant access to and responses from Liesl customer service representatives

• respond, where necessary, to information requests from governments or law enforcement authorities

Liesl is committed to protecting the personal data of its users, regardless of where they are located or where or by whom their personal data is processed. This includes implementing global measures to protect user data, including:

• securing user data during transmission, including through encryption, and at rest

• requiring company-wide training on data protection and data security

• implementing internal policies and procedures to restrict access to and use of user data

• restricting access by governments and law enforcement authorities to user data unless legally required, where immediate safety threats exist, or where users have consented to the access

When we transfer user data from the EEA, the United Kingdom, and Switzerland, this is done on the basis of the necessity to perform our agreements with users, on the basis of consent, adequacy decisions regarding the country of transfer (available here, here, or here), and on the basis of transfer mechanisms such as the Standard Contractual Clauses adopted by the European Commission (and their approved counterparts for the United Kingdom and Switzerland), and on the basis of the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”), as established by the U.S. Department of Commerce. Such data remains subject to the GDPR or equivalent regulations even after such transfer. Users may contact Liesl regarding the above information or request copies of the applicable Standard Contractual Clauses.

C. Updates to This Privacy Policy

We may update this Privacy Policy from time to time. If we make significant changes, we will notify users in advance through the Liesl apps or by other means, such as email. We encourage users to review this Privacy Policy regularly for the latest information on our data protection practices.

Use of our services after an update constitutes consent to the updated Privacy Policy to the extent permitted by law.