Privacy Policy

Last Updated: May 14, 2025

Effective Date: May 14, 2025

We place paramount importance on users’ privacy rights. When you utilize our products and services, we may gather and process your personal data and user data (collectively referred to as “Data”). This Privacy Policy elaborates on how we collect, utilize, share, store and manage your Data throughout your use of our offerings, as well as the methods you can adopt to exercise your rights over personal data. Kindly read this document thoroughly, with special attention to bolded or underlined paragraphs. By tapping the “Agree” button, you acknowledge that you consent to our collection, usage, sharing, storage and management of your relevant Data in compliance with this Privacy Policy (including all subsequent revised versions).

This Privacy Policy is directly tied to the products and services you access. We suggest you fully read and comprehend all clauses before using our services, and make appropriate choices based on the guidance provided herein if needed. We will adopt plain, straightforward wording to explain technical jargon and concepts for easier understanding.

Guidance for Minors

1. If you are under 18 years old, read this Policy alongside your parent or legal guardian, and make relevant decisions under their supervision.
2. Users under 14 may only access our products after their parent or legal guardian explicitly approves this Privacy Policy.
3. If you are the legal guardian of a minor, please ensure the minor under your custody uses our services with your full consent.
4. Should you have any doubts or concerns after reviewing this Policy, reach out to us via the contact channel listed below. We will address your inquiries as soon as possible.

Contact Email: jessicah@lastmiledsp.it.com

Table of Contents

1. Collection and Utilization of Your Personal Data
2. Application of Cookies and Comparable Tracking Tools
3. Sharing, Transfer and Public Disclosure of Your Personal Data
4. Safeguards for Your Personal Data
5. Access, Modification and Deletion of Your Personal Data
6. Personal Data Protection for Minors
7. Revisions to This Privacy Policy
8. How to Get in Touch With Us

1. Collection and Utilization of Your Personal Data

To deliver, optimize our services and safeguard your usage security, we collect data you actively submit or data automatically generated during your service experience through the following approaches:

1. For security defense and product optimization

To secure your usage experience as well as that of our affiliated platforms and partners, protect personal and property safety of all users and the general public, mitigate cyber risks including phishing scams, fraud, system vulnerabilities, computer malware, network attacks and intrusions, continuously upgrade our products (including crash/lag data collection to troubleshoot technical glitches) and boost product performance, we gather the following device information: device brand, device model, storage capacity, operating system type and version, screen resolution, IP address, unique device identifiers (MAC address, IDFA, IDFV), sensor data and network type. We may anonymize and aggregate such data to evaluate security risks, detect and resolve safety incidents, and carry out logging, auditing, analysis and disposal procedures.

1. Rules governing the use of collected personal data

(1) All collected personal data will be utilized strictly in accordance with this Policy and to realize core product and service functions.

(2) You acknowledge and agree that we may apply technical anonymization and de-identification to your personal data. Once processed into unidentifiable data, we may analyze user databases and conduct commercial research with such data without obtaining additional consent from you.

(3) You authorize us to process all personal data you provide during service use unless you delete relevant data or disable data collection via device settings. After account cancellation, we will cease all data usage and erase your personal records.

(4) If we intend to use your personal data for unstated purposes or repurpose data collected for a specific objective, we will obtain your explicit prior consent in advance.

1. Reminder on sensitive personal data

Before supplying any category of sensitive personal data to us, carefully assess whether such provision is appropriate, and consent to our processing of your sensitive data in line with the purposes and methods outlined in this Policy.

We will only collect and process sensitive data with your authorization to activate corresponding business features. You reserve the right to reject such collection, though refusal may restrict your access to related functions.

1. Scenarios exempt from user consent

We may collect and use your personal data without your approval under the following legally permitted circumstances:

(1) It is necessary to fulfill statutory duties or legal obligations;

(2) It is required to respond to public health emergencies or protect individuals’ lives, health and property amid urgent crises;

(3) Processing within reasonable boundaries for public-interest activities such as news reporting and public opinion supervision;

(4) Reasonable processing of personal data voluntarily disclosed by individuals or legally published information;

(5) Required to execute a contract you request to sign or perform;

(6) Other situations specified by applicable laws and regulations.

Please note that our products and services are continuously updated. If new functions collect unmentioned data, we will separately inform you of the data type, collection scope and purpose via page pop-ups, interactive prompts or official announcements to secure your consent.

If we discontinue product or service operations, we will immediately stop collecting your personal data, notify you via individual messages or public announcements, and delete or anonymize all stored personal data linked to the suspended business.

Device information alone cannot identify any specific individual. If we combine such non-personal data with other records to pinpoint your identity, the combined dataset will be treated as personal data during processing. We will anonymize and de-identify such integrated data unless we acquire your authorization or legal provisions state otherwise.

2. Application of Cookies and Comparable Tracking Tools

When you use our services, small data files will be stored on your computer or mobile device, including standard cookies, Flash cookies and other local storage files supported by browsers or client applications (collectively “Cookies”). Each Cookie generally contains a unique identifier, platform name and a string of numbers and characters.

You can disable Cookie storage via browser settings if you do not wish your data to be saved through Cookies. However, disabling Cookies may limit your access to our platform and prevent full use of our services. We commit to using Cookies solely for the purposes defined in this Policy, which are listed below:

1. Maintain stable and secure product operation

We deploy Cookies and anonymous identifiers for identity verification and risk prevention, enabling secure login authentication and detection of theft, fraud and other illegal acts. These tools also accelerate page loading and improve overall service efficiency.

1. Deliver a more convenient user experience

Cookies can record your login status to avoid repeated manual entry of personal information.

1. Cookie clearing instructions

Nearly all browsers support cache clearing functions in system settings. After clearing cached Cookies, you may lose access to all platform features dependent on Cookie technology.

3. Sharing, Transfer and Public Disclosure of Your Personal Data

We maintain strict confidentiality over your data and will never sell or rent out your information, except under the conditions specified below:

(A) Data Sharing

1. Legal mandatory sharing: We may share your personal data with external parties as required by laws, judicial proceedings, dispute resolution, or formal requests from administrative and judicial authorities.
2. Sharing with your explicit consent: We will only share your data with third parties after receiving your clear approval.
3. Public interest protection: Within legal boundaries, we may provide your data to external parties to safeguard the legitimate rights, property and safety of our platform, users and the general public.
4. Sharing with affiliated entities

To facilitate service delivery and push personalized content matching your preferences, we may share necessary personal data with our affiliates and their designated service providers. All sharing activities comply with the purposes stipulated in this Policy. If we share your sensitive data or affiliates alter the data processing purpose, we will re-apply for your authorization.

We only share anonymized, de-identified data for legitimate, necessary, specific and clearly defined goals. We sign rigorous confidentiality agreements with all third-party collaborators, mandating them to process data per our instructions, this Policy and relevant security protocols.

(B) Data Transfer

We will not transfer your personal data to any external entity unless:

1. You provide explicit consent for such transfer;
2. Corporate restructuring occurs (merger, acquisition or bankruptcy liquidation): If data transfer is involved, the new entity holding your data must abide by this Privacy Policy. If the new entity cannot comply, we will require them to obtain your separate authorization again.

(C) Public Disclosure of Personal Data

We will only publicly disclose your personal data after implementing legally compliant security measures in the following cases:

1. You grant explicit consent;
2. Disclosure is required by laws, judicial procedures, government mandatory orders, to address severe breaches of platform rules, or to protect personal and property safety of users and the public. We will demand official legal documents before processing any disclosure request in compliance with regulatory rules.

(D) Exemptions from prior consent for sharing, transfer and public disclosure

No pre-authorization is required under the following scenarios:

1. Matters related to national and national defense security;
2. Matters concerning public safety, public health and major public interests;
3. Judicial and administrative law enforcement activities including criminal investigation, prosecution, trial and judgment enforcement;
4. Protecting your or others’ vital legal rights to life and property where consent cannot be obtained in a timely manner;
5. Personal data you voluntarily released to the public;
6. Data extracted from legally public channels such as official news and government disclosures;
7. Academic research institutions conducting public-interest statistical studies, where all identifiable personal data in published research results are fully de-identified;
8. Other circumstances stipulated by laws and regulations.

If we process data via technical means to render recipients unable to re-identify individuals or restore original personal information, such shared, transferred or disclosed datasets do not require additional notification or consent from you.

4. Safeguards for Your Personal Data

1. Standard security protection mechanisms

We adopt mainstream industry security standards to shield your personal data against unauthorized access, disclosure, modification, damage or loss, and implement all reasonable feasible protective measures. Examples include SSL data encryption, regular privacy and security training for internal staff, tiered access control for personnel with data access rights, mandatory confidentiality contracts and real-time operation monitoring for relevant employees. We deploy state-of-the-art technical safeguards to minimize risks of data leakage, corruption and loss.

Please acknowledge that the internet cannot guarantee absolute security, and no protective solution is entirely risk-free.

1. Response protocols for data security incidents

In the event of personal data leakage or other security breaches, we will activate emergency response procedures to contain risk escalation. In accordance with legal requirements, we will notify you of incident details, potential hazards, corrective actions taken, self-protection guidance and remedial solutions via email, mail, phone or in-app push alerts. If individual notification is unfeasible, we will issue public announcements through official channels. Meanwhile, we will submit incident handling reports to relevant regulatory authorities as required.

5. Access, Modification and Deletion of Your Personal Data

1. Data management rights

During service usage, you may view, revise and delete your personal data directly on the platform, or contact us via the designated email address. The available operation scope varies by service type. We maintain appropriate technical systems to ensure data accuracy and timely updates.

You may also submit requests to view, correct or erase your data by emailing sanaychouchi1993@outlook.com.

If you discover errors in our data processing, you hold the right to request revision and supplementation. Our services may request permissions such as album and camera access; you may disable partial or all permissions anytime via device settings to block data collection. Permission configuration methods differ across devices, please refer to official device manufacturer guidelines.

1. Adjust the scope of your authorization

Send an email to sanaychouchi1993@outlook.com to modify or withdraw your data processing authorization.

After consent withdrawal, we will cease processing corresponding data. Note that revoking consent may disable matching platform functions, yet it will not invalidate prior lawful data processing activities conducted with your original approval.

1. Request copies of personal data

You can apply for a full copy of your stored personal data by email. We will deliver the copy within 15 working days upon receipt of your request.

1. Account cancellation

Registered users have the right to cancel their accounts by emailing sanaychouchi1993@outlook.com. We will conduct identity verification for account safety purposes, and complete cancellation procedures within a maximum of 15 days after successful verification.

After account cancellation takes effect, all account data will be permanently erased and unrecoverable. We will terminate all service provision and delete or anonymize your personal data promptly. Account cancellation is irreversible; please make your decision prudently.

1. Right to challenge automated algorithmic decisions

If our platform relies solely on automated systems and algorithms to make decisions that substantially impact your legitimate rights, you may request a detailed explanation and corresponding remedial solutions from us.

1. Complaint and reporting channel

If you suspect your personal data rights have been infringed, submit a complaint via sanaychouchi1993@outlook.com. We will complete verification and reply to your report within 15 days.

1. Data processing rules upon business shutdown

If we cease all operations, we will immediately halt data collection, notify users individually or via public announcements, and delete or anonymize all stored personal data.

1. Circumstances where we may decline your requests

We reserve the right to reject your application under the following legally permitted conditions:

(1) Requests involving national and national defense security;

(2) Matters related to public safety, public health and major public interests;

(3) Ongoing criminal investigation, prosecution and judicial trial procedures;

(4) Sufficient evidence proves you submitted malicious requests or abused your user rights;

(5) Fulfilling your request would severely harm the legitimate rights of other individuals or organizations;

(6) Requests involving our core commercial trade secrets.

6. Personal Data Protection for Minors

1. General provisions for minor users

(1) Users under 18 must read and agree to this Policy under parental or guardian supervision before accessing our services.

(2) We comply with national legal standards for minor data protection. We only collect, use, share or disclose minors’ personal data when permitted by law, with verifiable guardian consent, or necessary to protect minors’ interests. If we detect minor data collected without guardian approval, we will delete such records as soon as possible.

(3) If you act as a minor’s legal guardian, contact us promptly with any inquiries regarding the minor’s service usage and submitted data.

1. Special protective regulations

We attach high priority to minor data security and implement anti-addiction systems in compliance with national internet addiction prevention policies to safeguard minors’ legal interests.

Users under 14 are governed by both this Privacy Policy and the Children’s Privacy Protection Guidelines, and may only use our services after their guardians consent to the Guidelines. Users aged 14–18 are recommended to review the Guidelines with guardian guidance.

Children’s Privacy Protection Guidelines

Last Updated: October 14, 2025

This dedicated guideline is formulated to fully protect personal data security of minors (individuals under 18 years old), detailing our standards for collecting, processing, storing and sharing children’s data, as well as rights held by minors and their guardians. This document, together with the main Privacy Policy and User Agreement, constitutes the complete service terms. Users aged 18 and above shall follow the main Privacy Policy only.

I. Scope of Application

This guideline exclusively applies to all processing activities involving minors’ personal data. Important notes:

1. Children under 14: Must review this guideline and the main Privacy Policy with guardians, and obtain guardian consent before using any of our products or services.
2. Minors aged 14 to under 18: Recommended to read and understand this guideline under guardian guidance.

II. Collection and Use of Minors’ Personal Data

We only gather minor data voluntarily submitted by users or collected with guardian consent (refer to Chapter 1 of the main Privacy Policy for full details).

We may acquire anonymized research data from legally authorized third-party research institutions to optimize product experience, but will not actively obtain minors’ personal data from any other external sources without authorization.

We strictly limit data collection to information essential for core service functions. If you discover we have collected your child’s data without your consent, contact us immediately; we will delete the relevant records after verification.

III. Usage of Minors’ Personal Data

We process collected minor data in full compliance with laws, regulations, the User Agreement, the main Privacy Policy and this guideline to deliver services to minors. See the main Privacy Policy for specific usage rules. If we need to repurpose minor data beyond the original collection intent, we will notify guardians separately and obtain new consent.

IV. Storage of Minors’ Personal Data

1. Storage location

In compliance with national laws, all collected minor personal data will be stored domestically within China. We have no current plans for cross-border data storage or provision of minor data to overseas institutions.

1. Storage duration

Data will only be retained for the shortest period required to fulfill service objectives or meet statutory retention requirements. Upon expiration of the storage cycle, all data will be deleted or anonymized to eliminate individual identification capability.

V. Security Protection for Minors’ Personal Data

1. Protective technical measures

We deploy industry-standard encryption and access control systems to prevent unauthorized access, tampering, leakage and loss of minors’ data. We conduct regular staff privacy training, implement tiered data access permissions, sign confidentiality contracts with internal staff and monitor all data operation logs. While we deploy comprehensive technical safeguards, the internet cannot guarantee absolute data safety.

1. Security incident handling

If a minor data leakage incident occurs, we will activate emergency response protocols to control risks. We will inform guardians of incident details, potential risks, corrective actions and self-protection advice via email, phone or push notifications. Mass public announcements will be released if individual notification is impractical, and we will submit incident reports to regulatory authorities as required by law.

VI. Rights Relating to Minors’ Personal Data

1. Right to correction

If you or your child find incorrect personal data records, contact us via the official email; we will complete verification and revision without delay.

1. Right to data deletion

Guardians may apply to erase minors’ data under the following conditions:

• We processed data in violation of laws, regulations or service agreements;
• Data processing exceeds the necessary scope or legal retention period;
• Guardians have fully withdrawn consent for data processing;
• The minor voluntarily stops using our services (unless restricted by law).

If we discontinue service operations, we will delete or anonymize all remaining minor data legally and issue advance notifications.

For inquiries, data copies, corrections, supplementary information, deletion and consent withdrawal, refer to corresponding clauses in the main Privacy Policy, or email sanaychouchi1993@outlook.com for support.

1. Restrictions on data transfer and entrusted processing

We will not transfer or entrust minors’ data to third parties in general circumstances. If such operation is absolutely necessary, we will conduct strict security audits on third-party partners and enforce identical data protection obligations.

1. Limitations on public disclosure

Minors’ personal data can only be publicly disclosed when required by law or after guardians provide explicit written consent.

VII. Revision and Validity of This Guideline

We may revise this guideline to adapt to legal updates or business adjustments. Any revisions will be announced inside our products. Continued use of services by minors constitutes acceptance of updated clauses.

VIII. Supplementary Terms

This Children’s Privacy Protection Guideline acts as a supplementary clause to the main Privacy Policy. If conflicting provisions exist between the two documents, this guideline shall prevail. Matters not covered herein shall be governed by the main Privacy Policy and User Agreement.

IX. Contact Information

For inquiries, feedback or complaints regarding minors’ data protection, email sanaychouchi1993@outlook.com. We will respond to your application within 15 days and fully protect the privacy of all communication records.

7. Revisions to This Privacy Policy

1. Our products and services are continuously upgraded, so we will revise this Privacy Policy accordingly. All updated versions form integral parts of this Policy with equal legal force. Without your explicit approval, we will never reduce your legal rights defined in the effective version of this Policy.
2. All revised versions will be published on this page immediately after updates. We recommend you check this page regularly to stay informed of the latest terms.

8. How to Get in Touch With Us

For any questions, comments or suggestions related to this Privacy Policy, send emails to jessicah@lastmiledsp.it.com. We will review your feedback promptly and reply within 15 working days after verifying your user identity.