Levid Privacy Policy

Last Updated: January 2025

1. Introduction

Levid ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and share your personal data when you use the Levid platform. We comply with the EU General Data Protection Regulation (GDPR) and applicable data protection laws.

2. What Data We Collect

Personal Information: Full name, email address, phone number, date of birth, nationality, country of residence, and government-issued identification documents.

Financial Information: Bank account details, transaction history, account balances, card usage data, and income/source of funds information.

Technical Data: IP address, device information, operating system, app version, login timestamps, and usage patterns.

Biometric Data: With your explicit consent, facial recognition or fingerprint data for authentication. This data is stored only on your device and never transmitted to our servers.

3. How We Use Your Data

We use your data to:

• Provide and improve our financial services
• Process transactions and verify identities (KYC/AML compliance)
• Prevent fraud, money laundering, and other illegal activities
• Communicate with you about your account and transactions
• Develop and improve our AI agent's recommendations
• Comply with legal obligations and regulatory requirements

4. Legal Basis for Processing

We process your data based on:

• Contractual necessity: To provide the services you requested
• Legal obligation: KYC, AML, tax reporting
• Legitimate interest: Fraud prevention, service improvement
• Your explicit consent: Biometric authentication, marketing communications

5. Data Sharing

We share your data only with:

• Banking partners (Swan) — for EUR accounts and SEPA transfers
• Crypto exchange partners (Kraken, Yellow Card) — for currency conversion
• Payment partners (LemFi) — for last-mile payout
• Card issuing partners (Marqeta) — for virtual card services
• Identity verification providers (Onfido) — for KYC checks
• Regulatory and law enforcement authorities — as required by law

We never sell your personal data to third parties.

6. International Data Transfers

Your data may be transferred and processed in countries outside the European Economic Area (including Nigeria for payment processing). We ensure adequate safeguards are in place through Standard Contractual Clauses and partner compliance with GDPR-equivalent standards.

7. Data Retention

We retain your personal data for as long as your account is active, plus 7 years after account closure to comply with financial regulations and anti-money laundering requirements. Transaction records are retained for a minimum of 10 years. You may request deletion of data not subject to legal retention requirements.

8. Your Rights

Under GDPR, you have the right to:

• Access: Your personal data
• Correct: Inaccurate data
• Delete: Your data (subject to legal retention)
• Restrict: Processing
• Data portability: Receive your data in a machine-readable format
• Object: To processing
• Withdraw consent: At any time

To exercise these rights, contact privacy@levid.io. We respond within 30 days.

9. Security Measures

We implement:

• End-to-end encryption for all data transmission (TLS 1.3)
• AES-256 encryption for data at rest
• Biometric authentication support
• Regular security audits and penetration testing
• Strict access controls and employee background checks

10. Cookies and Tracking

Our mobile app does not use cookies. Our website may use essential cookies for functionality. We use Firebase Analytics for anonymous usage statistics. You can disable analytics in your device settings.

11. AI and Automated Decisions

Our AI agent processes your transaction data to provide personalized financial suggestions. AI decisions affecting your finances require your explicit approval before execution. You may disable AI features in Settings.

12. Children's Privacy

Levid is not intended for individuals under 18 years of age. We do not knowingly collect data from minors. If we become aware that a minor has provided personal data, we will delete it immediately.

13. Changes to This Policy

We will notify you of material changes via email and in-app notification at least 30 days before they take effect. Continued use after changes constitutes acceptance.