LY Privacy Policy

LY Living (FZE), (registered number 8751) (“us”, “our”, “we”, “LY”) is the controller of your personal data collected through the LY website, https://www.ly.ai or the LY app (Collectively referred as the “App”). LY is committed to protecting and respecting your privacy. This privacy and cookie policy (the “Policy”) sets out the types of personal data we collect and use when you access and visit the App and how we may use that data.

1. Introduction

This Policy explains who we are, why and how we process personal data collected through your use of the App and, if you are the subject of any of the personal data concerned, what rights you have and how to get in touch with us if you need to.

When you supply any personal data to us, we have legal obligations towards you in the way we use that data. For ease of reading, we have divided this Policy into several sections:

  1. Introduction
  2. What information can we collect?
  3. Special Category Data
  4. How is your personal information collected?
  5. How and why do we use and share your personal information?
  6. For how long do we keep your personal information?
  7. Security
  8. International Data Transfers
  9. Your Rights
  10. Contact Details

It is important that you read this Policy together with any other privacy notice or fair processing notices that we may provide on the App at or around the time that we collect or process personal data about you (for example, fair processing notices that we may display to you at the time that you sign up to receive e-mail updates from us) so that you are fully aware of how and why we are using that data.

This Policy supplements other notices on the App and is not intended to override or replace them.

By visiting or otherwise using the App, you agree to its terms (including as amended from time to time) and this Policy. If, for any reason, you do not agree to the terms of this Policy, please stop using this App.

We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant, we will endeavour to let users of the App know. However, it is your responsibility to check this Policy before each use of the App – for ease of reference the top of this Policy indicates the date on which it was last updated.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Please note that the Website is not directed at children under the age of 18 (each a "Child" or "Children") and we do not knowingly collect personal data about Children. If you believe we have collected personal data about your Child, you may contact us at hello@ly.ai and request that we cease processing data about your Child.

2. What information can we collect?

What is personal data? Where this Policy refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your name, your date of birth, your contact details and even your IP address. By law, all organisations who process your personal data in the UAE are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the “Your Rights” section of this Policy. What types of data we collect from you when you use the App

The personal data we collect from you may include:

Where you are required to pay a deposit to secure a booking, we use a third party payment services provider to collect and process any financial data (which includes your bank account and payment card details) and manage the transfer of funds. We have a contractual agreement in place with that payment services provider, which is directly responsible for the collection and processing of the financial data that you provide to it, and for executing the transfer of funds. We do not directly collect or process any of your financial data, nor do we handle any of the funds that you may send to venues to secure bookings, that data will be processed by our payment services provider and your deposit remitted to the venue directly.

3. Special Category Data

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

4. How is your personal information collected?

Direct interactions When you use the App to create an account, use our app, complete reservation and location requirements, make reservations, pay deposits, interact with us, contact us by email or by post, request marketing be sent to you, participate in competitions or prize draws or browse from page to page, we may collect, store and use the personal data that you disclose to us. Updating your information If you want to update the information you have previously given to us, you can or contact us at hello@ly.ai.

5. How and why do we use/share your personal data?

Lawful basis for processing your information We will only use your personal data when the law allows us to.

Most commonly we will use your personal data in the following circumstances:

Email Alerts

We will use in-app alerts and emails to deliver messages to you that relate to services that you request via the app. In simple terms that means that we will deliver messages to you to notify you about venues responding to your requests for a Reservation, as well as to notify you about updates or changes to Reservations that you have made (for example, if a cancellation occurs). Some venues will use their own technologies to deliver those updates to you. Typically those venues will do that using a broader set of technologies which they use to manage and list their vacancies and reservations. To ensure that you receive updates about your Reservations as promptly and as efficiently possible, and to streamline the process of identifying potential vacancies at venues, we enable venues to do this where they have the necessary technologies in place. In those cases you will receive email and/or sms notifications about your reservation request directly from the venues at which you have requested a reservation. Your data is provided to venues in this way solely to enable them to manage and alert you about your reservation. Please note that LY does not provide venues with your details to venues for use in promotional mailing lists. For more information about marketing emails please see ‘Marketing andCommunications’ below. If you believe that a venue has sent you promotional emails or sms messages using details received by it from LY, then please contact us to make us aware and to enable us to resolve the issue.

AI Chatbot & Personalized Recommendations

We use the data you provide—including your preferences, interactions within the app, and usage behavior—to deliver tailored lifestyle recommendations through LY’s AI-powered assistant. This includes both the in-app chatbot and voice assistant, which help you explore curated luxury listings and finalize bookings or purchases. For example, if you frequently explore specific cuisines, our AI systems may suggest exclusive restaurants based on your previous choices, location, and current trends. This personalization is essential to delivering the premium and seamless experience that LY promises.

Our lawful basis for processing this data is:

We do not use your data for automated decision-making that has legal or similarly significant effects. Recommendations are designed to support your lifestyle decisions, not to replace them. Your conversations with the chatbot or voice assistant are processed to enhance future recommendations, streamline your interactions across the app, and to support customer service if needed. These interactions are not shared with third parties for marketing purposes without your explicit consent.

Location Data

Data Collected

We may collect and process precise or approximate location data (e.g., GPS, Wi-Fi, Bluetooth) from your device when you use the app. We may also collect location data passively (e.g., derived from IP address) to improve services. How Location Data is Used To provide, improve, and personalize features and content within the app. To enable location-based services (e.g., maps, nearby listings, localized search results). To support security, fraud prevention, and non-repudiation. To analyze and understand usage trends and to optimize the app experience. Legal Basis for Processing Consent: We may process location data based on your consent, which you can withdraw at any time. Legitimate Interests: We may rely on legitimate interests to process location data for service delivery, safety, and analytics, provided your interests and fundamental rights are not overridden. Other Legal Bases: If applicable, we may rely on other legal bases permitted by law. Storage and Sharing Location data may be stored on our servers or on third-party services as necessary to provide the features of the app. We may share location data with: - Service providers who perform services on our behalf (e.g., analytics, hosting, map services) under appropriate safeguards. - Law enforcement or other third parties if required by law or to protect rights and safety. User acknowledgment and Agreement By using the app and allowing location access, you acknowledge that you have read and understood this Location Data section and consent to the processing of your location data as described herein. You agree that the processing of your location data in accordance with this policy will not be deemed a breach of any agreement or covenant with the app owners or any affiliated entities, except as required by law or this Agreement. This acknowledgment does not waive any rights you may have under applicable laws, including rights to access, correct, or delete your data. User Control and Choices You can enable or disable location access for the app in your device settings. You can opt out of location-based features within the app where available. You can request deletion or anonymization of location data we hold about you (subject to legal and operational retention requirements). Data Retention We will retain location data only for as long as necessary to fulfill the purposes described above and to comply with legal obligations, after which it will be securely deleted or anonymized.

Marketing and Communications

Where you opt-in to receive alerts (either by specifically requesting particular types of alert or communication, or by way of a ‘soft opt-in’ where you turn down the option to be removed from a particular mailing list) we will send you communications of the type that you have indicated you wish to receive. Those communications will, depending on your selection, include in app alerts, emails, and/or sms text messages. In addition to notifying you of news and promotions that relates to LY and the app, we will (where you have validly opted-in) send you similar news and promotions about venues which feature on the app. This may include suggesting venues that we believe will be of interest to you, notifying you of promotions being offered by venues, and similar direct marketing communications. Those communications are sent to you by LY and not by the venues described within them. We will not provide your personal data to venues for use by them in direct marketing campaigns (i.e. email or sms text message campaigns) without your explicit consent to do so. Please note that if you provide your contact details to venues independently of the app, for example by participating in a promotion offered by that venue while you are a guest there, then LY will have no control over or responsibility for any subsequent direct marketing materials that the venue in question may send to you. You will need to contact that venue directly in order to opt-out.

Opting Out of Marketing

To unsubscribe from marketing emails sent by Ambl at any time, please click on the unsubscribe link at the bottom of any marketing email and update your account preferences. You may also contact us directly if you do not wish to receive any marketing materials from us.

Sharing your personal data

Depending on how and why you provide us with your personal data we may share it in the following ways:We may also disclose your personal data to third parties in the following events:

Links to third party sites

Where we provide links to third party websites, plug-ins and applications that are not affiliated with the App such sites are out of our control and are not covered by this Policy. If you access third party sites using the links provided, the operators of these sites may collect personal data from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to those websites.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the associated website may become inaccessible or not function properly. For more information about the cookies we use, please see “Use of Cookies” below.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Use of Cookies

Our Site uses "cookies" to help you personalise your online experience. A cookie is a text file that is placed by us or our remarketing partners on your hard drive by a web page server. Our cookies do not run programs or deliver viruses to your computer. Cookies are uniquely assigned to your computer and can only be read by a web server in the domain that issued the cookie to your computer.One of the primary purposes of cookies is to provide a convenient feature to save you time. The cookie tells the server that you have returned to a specific page. For example, if you personalise the Site pages, or register with the Site, a cookie helps the Site recall your specific information on subsequent visits. This simplifies the process of recording your personal data, such as your billing address or site preferences. When you return to the Site, the information you previously provided can be retrieved, so you can easily use the Site features that you customised.

7. For how long do we keep your personal data?

We will hold your personal information on our systems only for as long as required to provide you with the services you have requested, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.By law we have to keep basic information about our customers (including contact, identity, financial and transaction Data) for five years after they cease being customers for compliance purposes. In some circumstances you can ask us to delete your data: see “Your Rights” below for further information, although this may not always be possible if we are obliged to retain the data for compliance purposes.In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific App feature.

8. Security

LY takes the protection of your information very seriously. We have put in place technologically and organisationally appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Where we have given you a password that enables you to access certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. International Data Transfers

We do not routinely transfer information outside of the UAE, where our company is registered. To support the operation of our platform, we use Amazon Web Services (AWS) data centers located in the UAE for the storage and processing of data. Where we do transfer your personal data to a service provider located outside of the UAE, we ensure that appropriate safeguards are in place to protect your personal information in line with applicable data protection laws. These safeguards include contractual commitments and internationally recognized data transfer agreements that ensure your data is processed securely and that your rights as a data subject are upheld. We will only transfer your personal data to countries that are deemed to provide an adequate level of protection for personal data, or where appropriate legal safeguards are in place. By submitting your personal information, you consent to this transfer, storage, and processing. If you would like more information about how your personal data is protected or transferred internationally, please contact hello@ly.ai

10. Your Rights

You have the right to make a complaint at any time to the UAE Data Office, the UAE regulator for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the UAE Data Office so please contact us in the first instance hello@ly.ai. As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.

Right of Access

You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a "subject access request"). Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data. You can exercise this right at any time by writing to us by contacting us and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.

Your Right to Rectification and Erasure

You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue processing it including storing it (you may have heard of this right described as the “right to be forgotten”). Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is correct. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request. You can exercise this right at any time by contacting us and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.

Your Right to Restrict Processing

Where we process your personal data on the basis of a legitimate interest (see the sections of this Policy which explain how and why we use your information) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid. You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data's accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms., We will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it. You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.

Your Right to Portability

Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Your Right to object to processing

You may object to processing of your personal data where we rely on legitimate interest for processing that personal data. We will comply with your request unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.

Your Right to stop receiving communications

Where we send you e-mail marketing communications (or other regulated electronic messages) you have the right to opt-out at any time. You can do this by using the ‘unsubscribe’ link that appears in the footer of each communication (or the equivalent mechanism in those communications). Alternatively, if for any reason you cannot use those links, or if you would prefer to contact us directly – you can unsubscribe by writing to us at hello@ly.ai and telling us which communications you would like us to stop sending you.

Your Right to object to automated decision making and profiling

You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.

Withdraw consent, where consent is the lawful basis for processing

You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Exercising your rights

When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity. It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you). You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Contact Details

If you have any queries regarding this Policy, if you wish to exercise any of your rights set out above or if you think that the Policy has not been followed, please contact us by emailing at hello@ly.ai. You may also lodge a complaint with the supervisory authority about the way we process your personal data. We would however, appreciate the chance to address your concerns before you approach the supervisory authority, so please contact us in the first instance.