Your data, in plain language.

1. Introduction

This Privacy Policy explains how Lever collects, uses, shares, and protects personal information when you use the Lever mobile application (the "App") and related services (together, the "Service"). Lever is operated by Lightstone Proprietary Limited ("Lightstone", "we", "us", or "our"), a South African data analytics and solutions service provider.

This Policy is specific to the Lever Service. It sits alongside Lightstone's Website and Application Privacy Notice (available at corporate.lightstone.co.za/privacy-notice), which applies to Lightstone's broader products and services. Where both this Policy and Lightstone's Privacy Notice apply, this Policy governs the Lever-specific Service experience. Where this Policy is silent on a matter, Lightstone's Privacy Notice applies.

Our processes and operations are in compliance with the Protection of Personal Information Act 4 of 2013 (the "POPI Act" or "POPIA"). We take data privacy seriously and are committed to safeguarding the privacy and security of personal information we collect from users of the Service.

2. Who this Policy applies to

This Policy applies to anyone who uses the Lever App, whether as a paying subscriber, trial user, or invited participant. Lever is designed for licensed estate agents operating in South Africa. If you are not a licensed estate agent or otherwise qualified to process property and personal information under South African law, you should not use Lever.

3. What personal information we collect

Information you give us

When you register for and use Lever, you provide the following personal information:

• Your full name
• Your email address
• Your mobile telephone number
• Your estate agency name
• Your Fidelity Fund Certificate (FFC) number, where applicable
• A profile photograph, if you choose to upload one

Content you create using Lever

• Chat messages exchanged with Lever's AI assistant
• Voice recordings you submit for transcription
• Photographs of properties you upload
• Notes and observations about properties, sellers, and buyers
• Property listings you build within the App

Property information you access through Lever

When you use Lever to look up properties, we retrieve information from Lightstone's property data services on your behalf. This includes property records, comparable sales, municipal valuations, and (where applicable) ownership information. You are responsible for the lawful use of this information under POPIA as the Responsible Party for any processing you initiate. Lightstone's collection and processing of this information is described in Lightstone's Privacy Notice.

Payment information

Subscription tier, status, and history. Billing information is processed by our payment provider, Clerk. Lever does not store payment card details.

Information collected about you and your device

Each time you use the App, we may automatically collect:

• Technical information, including device model, operating system version, App version, and IP address
• Product usage events (feature interactions, session duration) collected via Aptabase
• Error and crash reports

4. Legal basis for processing

Under POPIA, personal information may only be processed where one of the recognised conditions for lawful processing is met. We process your personal information on the following bases:

• Contract, to provide the Lever Service you have subscribed to
• Consent, for optional features such as AI processing and profile visibility
• Legitimate interest, to secure the Service, prevent misuse, and improve the product
• Legal obligation, to comply with applicable laws

Lightstone has published guidance on the eight conditions for lawful processing under POPIA. See corporate.lightstone.co.za/property-popia for further reading.

5. How we use your personal information

We use your personal information to:

• Provide, maintain, and improve Lever's features
• Process AI-driven features, including chat, voice transcription, photo analysis, valuations, listing copy, and market research
• Process your subscription and payments
• Communicate with you about the Service, updates, and support
• Detect and prevent fraud, abuse, or unauthorised access
• Comply with legal obligations, including POPIA and the Estate Agency Affairs Act

6. Who we share your personal information with

Lever uses third parties to deliver the Service. Under POPIA, these third parties fall into two categories:

• Operators are third parties that process personal information on Lever's behalf under our instruction. They do not use your personal information for their own purposes.
• Partners are third parties that are separate Responsible Parties. When you choose to use their services through Lever, or when Lever retrieves information from them on your behalf, they process personal information for their own purposes, subject to their own privacy notices.

Operators (process on Lever's behalf)

Partners (separate Responsible Parties)

7. How Lever uses AI

Lever uses artificial intelligence to help you work faster. This includes transcribing voice notes, analysing property photos, generating valuations and listing copy, and answering questions with market context. To provide these features, some of the information you enter is sent to trusted AI service Operators listed in Section 6.

Your explicit consent is required

Before Lever sends any data to an AI Operator, we ask for your explicit consent through an in-app disclosure screen on first use. You can review this disclosure at any time under Settings > Data and AI, and you can withdraw your consent at any time. Withdrawing consent will disable AI features until you review and re-accept the disclosure.

What is sent, and to whom

What is never sent to AI Operators

• Owner names retrieved from Lightstone property records
• Owner contact details, including telephone numbers, email addresses, and physical addresses of registered owners
• Your Lightstone or Prop Data account credentials
• Payment information

Data protection commitments from AI Operators

Each AI Operator provides data protection equivalent to or exceeding those Lever offers under this Policy:

• OpenAI. Data submitted through the API is not used to train OpenAI models. Data is retained for up to 30 days for abuse monitoring, then deleted. See openai.com/enterprise-privacy.
• Anthropic. Data submitted through the API is not used to train Anthropic models. See anthropic.com/legal/privacy.
• Perplexity. Data submitted through the API is processed only to return search results and is not used to train Perplexity's models. See perplexity.ai/hub/legal/privacy-policy.

Where an Operator updates its terms, we will review the update and notify users if the change is material.

8. What we do not do with your data

• We do not sell your personal information to third parties
• We do not use your content to train external AI models
• We do not share owner contact details or personal information retrieved from Lightstone with AI Operators
• We do not use your data for marketing purposes without your consent
• We do not disclose your notes or client interactions to Lightstone Property, Prop Data, or other third parties, except as described in this Policy or as required by law

9. Retention

We retain your information for so long as it is necessary to provide the Service to you, complete transactions you have requested, comply with our legal obligations, maintain appropriate business and financial records, resolve disputes, maintain security, and detect and prevent fraud and the abuse of our Service.

• Account and content: retained for the duration of your subscription plus 90 days after cancellation, after which your account and content are permanently deleted
• Payment records: retained for a minimum of 5 years, as required by South African tax legislation
• Audit logs: retained for 3 years to support security and dispute resolution
• AI Operator processing: content sent to AI Operators is subject to each Operator's retention policy, typically 30 days or less for API traffic, and is not used for model training

10. International transfers

Some of the Operators, payment infrastructure, and cloud services we use are located outside South Africa, primarily in the United States and European Union. By using Lever, you consent to your personal information being transferred outside South Africa for these purposes. We only transfer data to countries with privacy laws similar to or more stringent than South Africa's, or to Operators contractually bound to provide safeguards equivalent to POPIA.

11. Your rights under POPIA

Under POPIA, you have the right to have your personal information processed in accordance with the conditions for lawful processing. In particular:

• Section 11(3) gives you the right to object to your personal information being processed. You may lodge an objection at any time.
• Section 23 gives you the right to request, free of charge, whether we hold any of your personal information; and to request the record or a description of the information held, including the identity of third parties who have access to it.
• Section 24 gives you the right to request that we correct or delete personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully; and to request that we destroy or delete a record of your personal information if we are no longer authorised to retain it.

You may also:

• Withdraw consent for optional processing (including AI features)
• Lodge a complaint with the Information Regulator (South Africa)

To exercise these rights, please use Lightstone's POPIA request infrastructure at corporate.lightstone.co.za/pi. Requests will be handled by the Lightstone Group Information Officer and routed to the Lever product team where relevant. You are required to provide adequate proof of identity to exercise these rights.

You may also contact us directly at privacy@leverapp.co.za. We will respond within 30 days.

The Information Regulator can be reached at:

• JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
• inforeg@justice.gov.za
• +27 (0)10 023 5200

12. Notification under Section 18 of POPIA

Section 18 of POPIA requires us to notify you of certain information when we collect personal information from you. This Policy, together with the in-app AI disclosure screen described in Section 7, provides that notification. Specifically:

• The information we collect is described in Section 3
• The name and address of the Responsible Party (Lightstone Proprietary Limited) are provided in Section 15
• The purpose for which we collect the information is described in Section 5
• The recipients of the information (Operators and Partners) are described in Section 6
• The information you provide is required to provide the Service; failure to provide it may limit or prevent your use of the Service
• Your rights to access, correct, and object are described in Section 11

13. Security

Lever implements industry-standard security measures including encryption in transit (TLS), encryption at rest for sensitive data, access controls, and regular security reviews. No security measure is perfect. In the event of a data breach involving your personal information, we will notify you and the Information Regulator as required by POPIA.

14. Children

Lever is not intended for use by anyone under 18. We do not knowingly collect personal information from minors.

15. Contact us

Lightstone Proprietary Limited

• Information Officer queries and formal POPIA requests: via corporate.lightstone.co.za/pi
• Lever product privacy queries: privacy@leverapp.co.za
• Lever product support: support@leverapp.co.za

For Lightstone's broader Privacy Notice, see corporate.lightstone.co.za/privacy-notice.

16. Changes to this Policy

We may update this Policy from time to time. Material changes will be communicated in-app and by email. Continued use of Lever after a change constitutes acceptance of the updated Policy.

Contact

Reach us about anything on this page at privacy@leverapp.co.za.