Privacy Policy - ltworks

Privacy Policy

November 1, 2021

ltworks(北京字量数智科技有限公司) entities (for purpose of applicable data protection laws, ltworks(北京字量数智科技有限公司) entities providing ltworks Service which are subject to applicable disclosure requirements can be viewed HERE collectively, “ltworks”, or “we”, “us”, “our”) provide this privacy policy to explain how we collect, use, and share information. For the purposes of European data protection laws, ltworks is the data controller of your personal information. This privacy policy (“Policy”) covers ltworks’s handling of two types of information:

  • Information we receive when we provide our service, including (i) information about end users we collect through our software development kit (“SDK”), application programming interface (“API”), our platforms, services or technologies from traffic supply partners such as mobile app developer, ad exchange platform,ad mediation platform, supplied side platform; (ii) information about end users’ interaction with ads collect through our SDK, API or other technologies, or collected and transferred to us by our Business Partners (e.g. mobile app developers, advertisers, hereinafter referred to as “Business Partners”) or any third party designated by them; (iii) information generated during end users’ use of our Business Partners’ mobile apps, websites, platforms or services which is collected and transferred to us by our Business Partners or any third party designated by them; (iv) information provided by Business Partners when they use ltworks’s platforms, technologies, services. In the Privacy Policy of the ltworks Services, the end users mentioned in this section are collectively referred to as “User”, “you” or “your”; the SDK, API, any technology, platform or service provided by ltworks mentioned in this section are referred to as “ltworks Service”. Information we receive through the following websites from webiste visitors (hereinafter referred to as “Visitors”, “you” or “your”) in the Privacy Policy of ltworks Website): (i) our website at: www.ltworks.co (2)or any other website on which this Policy is posted, as well as (ii) any website we provide to Business Partners or potential clients in order to provide our services.

This Policy is subject to any service agreement between ltworks and you. By using the ltworks Service or ltworks Site, you acknowledge that you have read, understood and agreed to this Privacy Policy. Please review this Privacy Policy before using the ltworks Service or the ltworks Site. 

We evaluate this Policy and procedures to implement improvements and refinements from time to time. If we make material changes to this Policy we will notify you by means of a prominent notice on ltworks Site prior to the change becoming effective.

Data protection and ensuring our Business Partners’ and your trust is at the core of ltworks’s business principles. Accordingly, being compliance with applicable data protection laws is our top priority and this Policy is updated to be compliance with the applicable data protection laws, including EU General Data Protection Regulation (“GDPR”), the Children’s Online Privacy Protection Act (“COPPA”), the California Customer Privacy Act (“CCPA”), the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais) (“LGPD”) and the Chinese Personal Information Protection Law (“Chinese PIPL”).

Privacy Policy of the ltworks Services

1.Introduction

This Policy describes ltworks’s information collection and use while (i) Users view ads served by the ltworks Services or interact with ltworks’s Services in any manner; (ii) Users interact with platforms, applications, websites or other services provided by Business Partners; (iii) Business Partners interact with ltworks’s Service.

Our technology enables our partners to show Users more relevant advertising that is based on Users’ interests and behaviors. In order to provide ltworks Services, we may collect and use certain information about User activity and preferences. We understand how important it is to keep such User’s personal information confidential and discrete, especially in today’s online world. To this end, we have designed this Policy in a format that is easy to navigate and read so that our privacy practices can be clearly understood.

The ltworks Services may link to third party websites, Apps or other third party content. Please note that we cannot control the treatment of a User’s information by such third parties, and that the privacy practices of third parties likely differ from those described in this Policy.

2.How And Why We Collect Users’ Information

Depending on the nature of a User’s interaction with the ltworks Services, or any service provided by ltworks’s Business Partners, we may collect information directly from such User or from our Business Partners (e.g. mobile application developers, Ad Exchange platforms, and advertisers). For example, when we partner with an Ad Exchange platform and the Ad Exchange platform initiates an ad request to our DSP, it may share User’s information with us.

As a mobile ad platform, the reasons and purposes for us to collect Users’ personal information are for displaying ads on Users’ device, including building profile about Users in order to serve interest-based ads based on information we collect; monitoring traffic and measuring the performance and effectiveness of ads including preventing any fraud; understanding and analyzing Users’ usage trends and preferences; improving our service and develop our new products; ensuring the safty and security of process and system.

When we collect information about our partners’ business representatives such as name and email address, our purpose is to contact them for business communication including necessary communication for purpose of performing the agreements with our partners.

3.Information We May Collect From Users

When you view ads served by ltworks Service or interact with services provided by ltworks’s Business Partners, we and/or our Business Partners may collect your information.

We or our Business Partners may collect your personal information including the following: device make, device model, operating system (e.g. iOS) and the OS version of the device, device type (e.g. smartphone, tablet, etc.), screen size, orientation and battery, carrier information, version and characteristic of the app used by you when you interact with ltworks’s Service, country, time zone and locale settings (country and preferred language), network connection type, IP address, SDK version, timestamp, network status such as WiFi, mobile advertising identifier (e.g. Apple IDFA or Google advertising ID), device event information such as crashes, system activity, hardware settings, the date and time of your request and referral URL, user-agent, package name of the app of ltworks’s Business Partners, IDFV, system file size, system update time, system boot time, device user name, RAM (random access memory), remaining available RAM, CPU version. We or our Business Partners may also collect international mobile equipment identity (IMEI), Android ID and installed application list of Users for Android device solely for mainland China.

With regard to the information related to installed application collected by us:

• For Users of Android device, after our SDK loads an ad, we may check if you have installed the app promoted by our ad before showing this ad to you, and if you have already installed the app, we will not show this ad to you (“Impression-Filter”), and we will inform the service end not to serve this ad when the ad request is sent by your device in the future. ltworks only collects information related to the ad which is Impression-Filtered, and ltworks does not collect any other information related to any installed application.

• If our Business Partner’s app integrates our old version SDK, we may collect the information related to installed applications in your device which is the same as some of our Business Partners’ apps in order to send targeted ads to you (Users of apps with COPPA setting in ltworks platform are not applicable). For Users outside of mainland areas of China, the new version SDK (version 14.4.2 and any of its updated version) does not collect this information any longer. ltworks continuously encourages our Business Partners to update the SDK in their apps in order to better provide our advertising service.

When you view ads served by us or have other interaction with ads served by us, we may collect information about your interaction with such ads, for example, information that you have viewed or clicked an ad.

When you install and use the product (e.g. app) after you view and click an ad served by us, we may collect information about your downloading, installation, activation of an app or other activities about you within the app from our advertisers or any third party designated by them.In particular, where ltworks acts as Demand Side Platform (“DSP”) serving ads to Ad Exchange, our Business Partners acting as our Ad Exchange may collect and share your personal information with us including the following: screen size & orientation, device make, model, operating system, operating system version, device type, version and characteristic of the app used by you when you interact with the ltworks Services, carrier information, network connection type, IP address, user-agent; country, time zone and locale settings (country and preferred language) and mobile advertising identifier (e.g. Apple IDFA or Google advertising ID). We may also collect information about your interaction with ads served by us, such as information that you have viewed or clicked an ad.

We cooperates with reputational ad exchange platforms including Google Doubleclick Ad Exchange. The ad exchanged platforms may receive an ad request containing your personal information and, to the extent permitted by applicable law or with User’s valid consent, transfer to ltworks to build your profile, personalize your ad experience, and serve future ads you may see on the internet. The following privacy policies linked provide you information about our ad exchange platforms’ processing of your personal information.

We provide ltworks Service for Business Partners such as mobile application developers and advertisers. We may collect name, job title, email address, account name and password, IP address and address of individuals on behalf of such Business Partners, such as employees.

About Sensitive Personal Information

Sensitive Personal Information refers to personal information that, once leaked or illegally used, will easily lead to infringement of the human dignity or harm to the personal or property safety of a natural person. The scope of sensitive personal information may vary pursuant to different applicable data protection law.

We will not collect your sensitive personal information without your consent. Our Business Partner will transmit or authorize us to process your sensitive personal information after notifying you the necessity of processing your sensitive personal information and the impact of your rights and interests with your consent.

4. How We Use Users’ Personal Information

Your device might be distinguished from other devices based on information it automatically send, such as IP address, browser or device information. Your device may be identified based on a scan of your device’s unique combination of characteristics. Identifier for Advertiser or other information may be stored or accessed on your device for purposes presented to you under this Policy. Your device can receive and send information that allows you to see and interact with ads and content. We use your personal information to display ads on your device. Ads may be shown to you based on the content you’re viewing, the app you’re using, your approximate location, or your device type. We may build profile about you and your interest and to show you personalized ads or behavioral ads which are relevant to you and customized to your inferred interests, preferences, locations and other features based on profile about you. Where required, our Business Partners (e.g. developer of mobile app integrated with ltworks’s SDK, advertisers) will obtain User consent for and on our behalf for our processing of User personal information for profiling and displaying ads, including personalized ads or behavioral ads, on a User’s device. A User can withdraw their consent at any time.

Where necessary in our legitimate interests we use your personal information: (i) to measure the performance and effectiveness of ads that you see or interact with, including measuring the traffic quality in order to perform our contractual obligations to our Business Partners; (ii) to understand and analyze your usage trends and preferences, improve our ltworks Service, and to develop new products; (iii) for purpose of monitoring and preventing fraudulent activity, and ensuring systems and processes work properly and securely.

We may also collect and use personal information of Users who are representing our Business Partners to use ltworks Service (e.g. employees of mobile app developer or advertisers) for purpose of business contact and direct marking (e.g. sending marketing emails). Where required, our Business Partner will obtain such Users’ consent for and on our behalf for our processing of their personal information.

We may also use personal information about Users to comply with applicable laws, regulations or codes of practice, and to protect our legitimate interest and protect the rights or property of us or any other third parties.

5. Disclosure of Users’ Personal Information

Subject to compliance with applicable laws and regulations, we may disclose User’s personal information to any third party other than ltworks’s affiliated companies. 

We may disclose the User’s personal information to our Business Partners, to report the measurement of the performance and effectiveness of ads that User see or interact with, including measuring the traffic quality in order to perform our contractual obligations to our Business Partners, and to prevent fraudulent activity. The personal information we disclose is personal information related to the performance and effectiveness of advertisement, such as device information, information of click or impression. These Business Partners may use the Users’ personal information to measure Users’ ad/site interaction and evaluate the performance and effectiveness of ads that User see or interact with, identify Users’ interest areas, better understand the site and app traffic usage or User behavior in order to improve their services. Our Business Partners’ use of the information that we disclose to them will be governed by their privacy policies.

We may also use third party technical service providers (e.g. cloud service provider) to process the Users’ personal information for purpose of ensuring systems and processes work properly and securely, and for purpose of data storage.

According to the Chinese PIPL, we will not disclose User’s personal information to any third party other than ltworks’s affiliated company without User’s consent, except for those information that does not identify an individual and could not be recovered. About the name, contact information and other information of our Business Partner and any third party technical service provider, Chinese User can inquire via privacy@ltworks.co.

We may also share aggregate or anonymous information with other third parties in accordance with the terms of this Policy.

Our affiliates may also have access to Users’ personal information for the purposes set out in this Privacy Policy.

We may share Users’ personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others, including to advisers, law enforcement agencies, judicial and regulatory authorities. We may also transfer Users’ personal information to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganisation or otherwise.

6. International Transfers

When you are located in the European Econocim Area (“EEA”), personal information collected about you will be transferred to recipients in countries located outside the EEA or can be remotely accessed in countries located outside the EEA, including in countries which may not be decided by the European Commission that it provides an adequate level of protection to personal information. We have followed requirements as set out in applicable law to provide adequate protection to your personal data. To the extent as required by applicable law, our Business Partner will obtain your valid consent to the extent for us to transfer your personal information to recipients including ltworks’s affiliates and any other recipients as described in this Privacy Policy, which are located outside the EEA. You are entitled to withdraw your consent at any time.

ltworks has entered into EU standard contractual clauses (“Model Contracts”) for intra-group transfers of personal information to its affiliates. You can request a copy of these Model Contracts by submitting your request via email to privacy@ltworks.co

If you are located in the mainland areas of China, we store your personal information inside the mainland areas of China. Where it is necessary to provide your personal information to recipient outside mainland areas of China, we will transfer your personal information according to the requirement of any applicable data protection law.

7. Your Data Rights

If you are in the EEA, you have a right to (subject to a limited number of exceptions as permitted by GDPR): (i) request access to and rectification or erasure of your personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) ask for a copy of your personal information to be provided to them, or a third party, in a digital format. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority in the EEA.

If you are residents of the State of California in the United States, effective from January 1, 2020, you have a right to:

(i) exercise certain consumer rights such as request to know, disclose, access or delete your data, collected in the last 12 months, by writing to us at: privacy@ltworks.co and (ii) opt out of selling of your data by clicking on the following link: DO NOT SELL MY DATA

If you are in the mainland areas of China, you have the following rights related to your personal information except when laws and administrative regulations otherwise provide.

  1. Right to be informed, right to decide and right to restrict or refuse processing of yourpersonal information.
  2. Right to accessand copy your personal information except in special circumstance provided by la
  3. Right to request to transferyour personal information to another data handler.
  4. Right to request to revise and supplement yourpersonal information when you notice that the personal information we process is inaccurate or incomp
  5. Rightto delete your personal information in the following circumstances:
  6. Where the purpose of processing has been achieved or is unable to be achieved, or the personal information is no longer necessary for achieving the purpose of processing;
  7. Where ltworksceases the provision of its product or service involved, or the retention period has expired;
  8. Where consent is withdrawn by the User;
  9. Where the processing of personal information by ltworksis in violation of any law, administrative regulations or any agreement; or
  10. Any other circumstance as provided by law or administrative regulations.

If it is technically difficult to delete the personal information, tltworks shall cease the processing of the personal information, except for the storage and any necessary measure taken for security protection.

You can contact us via privacy@ltworks.co and request your data rights.

Setting about Personalized Ads

If you are in the mainland areas of China, you can manage ltworks’s ads your see and set for the personalized ads by clicking here.

No matter you are in which country or region, you can opt out personalized ads in the following way:

Guidance of Opt out

You can opt-out from receiving interest-based advertising or behavioural advertising from ltworks on supported devices following the guideline below.

  1. Your iOS mobile device may provide a “Limit Ad Tracking” setting. On Android devices, your settings may allow you to “Opt out of Interest-Based Ads.” When you have opted out using this setting on a device, ltworks will not use in-app information collected from that device to infer your interests or serve ads to that device that are targeted based on your inferred interests.
  2. Your mobile web browser may also provide a “Do Not Track” browser setting. When you have enabled this setting in your browser, ltworks will not use mobile web browsing information from that browser to infer your interests or serve ads to that device that are targeting based on your inferred interests.

If you have question about your data right, please contact privacy@ltworks.co

8. Security of Users’ Personal Information

The security of User’s information is our utmost priority, and we take strict measures in order to protect our data from unauthorized access, use, disclosure or destruction of data. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. For example, we use firewalls, encryption technology and other automated software designed to protect against fraud and identity theft; our data is only stored in centers that provide high-level security for User’s information. Physical access is strictly controlled both at the perimeter and at building ingress points by our staff utilizing video surveillance and other electronic means.

We also protect User’s privacy by seeking to minimize the amount of sensitive data that we store on our servers in the first place. We also seek appropriate contractual protection from our partners regarding their treatment of user data.

ltworks may retain the information relating to you collected from our Business Partners as necessary for the provision of the services, internal analytical purposes, or to comply with its legal obligations, resolve disputes and enforce agreements (e.g. settlement). We will only keep your personal information for as long as necessary and in any event in relation to personal information collected by us according to this Policy we will only keep this personal information for no less than two (2) years. The criteria used to determine the retention periods include: (i) how long the personal data is needed to provide the services and operate the business; (ii) the type of personal data collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

9. Protection for Minors

ltworks’s service is not mainly for minors. If a User is deemed as minor under applicable law, please make sure that before the use of the application which integrates ltworks’s product or service or the application of an advertiser that partners with ltworks for delivering its ads, parents or other guardian and such User have together read the application’s privacy policy with the guardianship and guiding of parents or other guardian, and their consent have been provided for processing of personal information.

We process minor’s personal information according to requirements of related laws and regulations. Except as otherwise provided by law, we will only collect, use, store, disclose, or make available to the public the personal information where permitted by law, with consent of parents or other guardians, or for the necessity of protection of the minors. If we notice the collection of personal information of minors without verifiable consent of parents, we will take measures to delete related information as soon as possible.

If you are parents or other guardian of minors, please contact us via the email we provide in this Privacy Policy when you have any question regarding to the protection of minors.

If you are Users in the U.S., we ensure that we comply with the Children’s Online Privacy Protection Act (COPPA). Publishers with apps directed to children under the age of thirteen (13) must enable the COPPA settings when using the ltworks Services. This allows ltworks to ensure that any persistent identifiers collected about Users of apps that are flagged as “child-directed” will be processed according to the requirements of COPPA, including not being used to serve behaviorally-targeted ads or track users for such purposes. In addition, we will not knowingly collect any other personal information (such as the precise geo-location of Users’ devices) from Users of Apps that we know to be directed to children under the age of thirteen (13).

If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should promptly contact us and we take reasonable steps to ensure that such information is deleted from our files.

10. Marketing

If you are our Business Partners, we may contact you periodically by e-mail to provide information regarding our products, services and content that may be of interest to you. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent.

If you decide at any time that you no longer wish to receive such communications from us, you may follow the unsubscribe instructions provided in any of the communications or request to be opted-out of receiving such communications via email to privacy@ltworks.co

Privacy Policy of ltworks Website

1. Introduction

This Privacy Policy of ltworks Website applies to information collection and use including while you are visiting and using the ltworks Site. For the purposes of European data protection laws, ltworks is the data controller of your personal information.

2. What Information We Collect

As you navigate through this ltworks Site, some of your personal information may be actively collected (for example, names, birth dates, personal ID card numbers, addresses, telephone numbers, E-mail addresses, occupations, education, work experience and related information), or passively collected (which you did not actively provide) such as your browser type, domain name, IP address, pages visited, and the length of your user session using various technologies and means, such as Internet Protocol Address, cookies, Internet Tags and navigational data collection. In order to improve our service quality, it may be necessary to ask for personal information to fulfil your requests and provide a better service. ltworks is entitled to take measures to validate the authenticity of personal information you provide. If you give us personal information of somebody else, we will assume that you have their permission to do so. Transmissions to and from this Site may not be confidential and consequently, may be read or intercepted by others.

We may also use Google Analysis that assists us with analysing the usage of our website and help to improve the service quality of our website. For the personal information that may be collected by Google Analysis and its processing activities, please visit: https://support.google.com/analytics/answer/6004245?hl=en&ref_topic=2919631

3. How We Use Your Information

The provision of personal information by you may be necessary where in our legitimate interest for the following purposes: (i) to provide you with ltworks products or services or information in relation to the same; (ii) to sign you up for an event or training; (iii) to contact you and respond to your requests and enquiries; (iv) for business administration, including statistical analysis; (v) to personalize your visit to the ltworks Site and to assist you while you use the Site; or (vi) to improve the ltworks Site by helping us understand who uses the Site.

We may also contact you periodically by e-mails to provide information regarding our products, services and content that may be of interest to you. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent.

If you decide at any time that you no longer wish to receive such communications from us, you may follow the unsubscribe instructions provided in any of the communications or request to be opted-out of receiving such communications via email to privacy@ltworks.co

4. Disclosure of Your Personal Information

Subject to compliance with applicable laws and regulations, we may disclose User’s personal information to any third party other than ltworks’s affiliated companies.

We may use selected third parties to provide us with services who may have access to your personal information, including companies that assist with programming and technical aspects of hosting and operating the ltworks Site, technical service provider (e.g. Google Analysis) that assists with analyzing the usage of our website, or email service provider. Our affiliates may also have access to your personal information including through or in connection with this ltworks Site for the purposes set out in this Privacy Policy.

According to the Chinese PIPL, we will not disclose User’s personal information to any third party other than ltworks’s affiliated company without User’s consent, except for those information that does not identify an individual and could not be recovered. About the name, contact information and other information of our Business Partner and any third party technical service provider, Chinese User can inquire via privacy@ltworks.co.

We may also share aggregate or anonymous information with other third parties in accordance with the terms of this Policy.

Our affiliates may also have access to Users’ personal information for the purposes set out in this Privacy Policy.

The servers used in the operation of the ltworks Site automatically identify a computer by its IP address. Although, we will not be able to identify the computer using its IP address once you have left the ltworks Site. If we, in good faith, determine that you have or are attempting to misuse or harm the Site, we may investigate and cooperate with appropriate law enforcement agencies to protect our rights or property.

Similarly, we may share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others, including to advisers, law enforcement agencies, judicial and regulatory authorities. We may also transfer your personal information to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganization or otherwise.

Similarly, we may share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others, including to advisers, law enforcement agencies, judicial and regulatory authorities. We may also transfer your personal information to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganization or otherwise.

5. International Transfers

When you are located in the mainland areas of China, we store your personal information inside the mainland areas of China. Where it is necessary to provide your personal information to recipient outside mainland areas of China, we will transfer your personal information according to the requirement of any applicable data protection law.

When you are located in the European Econocim Area (“EEA”), personal information collected about you will be transferred to recipients in countries located outside the EEA or can be remotely accessed in countries located outside the EEA, including in countries which may not be decided by the European Commission that it provides an adequate level of protection to personal information. We have followed requirements as set out in applicable law to provide adequate protection to your personal data. To the extent as required by applicable law, our Business Partner will obtain your valid consent to the extent for us to transfer your personal information to recipients including ltworks’s affiliates and any other recipients as described in this Privacy Policy, which are located outside the EEA. You are entitled to withdraw your consent at any time.

ltworks has entered into EU standard contractual clauses ( “Model Contracts”) for intra-group transfers of personal information to its affiliates. You can request a copy of these Model Contracts by submitting your request via email to privacy@ltworks.co.

6. Your Data Rights

You have the right to access, modify, correct or delete any personal data which we may have collected. To exercise this right please contact privacy@ltworks.co

If you are in the EEA, you have a right to (subject to a limited number of exceptions): (i) request access to and rectification or erasure of your personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) ask for a copy of your personal information to be provided to them, or a third party, in a digital format. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority in the EEA.

If you are residents of the State of California in the United States, effective from January 1, 2020, you have a right to:

(i) exercise certain consumer rights such as request to know, disclose, access or delete your data, collected in the last 12 months, by writing to us at privacy@ltworks.co (ii) opt out of selling of your data by clicking on the following link: DO NOT SELL MY DATA

If you are in the mainland areas of China, you have the following rights related to your personal information except when laws and administrative regulations otherwise provide.

  1. Right to be informed, right to decide and right to restrict or refuse processing of your personal information.
  2. Right to access and copy your personal information except in special circumstance provided by law.
  3. Right to request to transfer your personal information to another data handler.
  4. Right to request to revise and supplement your personal information when you notice that the personal information we process is inaccurate or incomplete.
  5. Right to delete your personal information in the following circumstances:
  6. Where the purpose of processing has been achieved or is unable to be achieved, or the personal information is no longer necessary for achieving the purpose of processing;
  7. Where ltworksceases the provision of its product or service involved, or the retention period has expired;
  8. Where consent is withdrawn by the User;
  9. Where the processing of personal information by ltworksis in violation of any law, administrative regulations or any agreement; or
  10. Any other circumstance as provided by law or administrative regulations.

If it is technically difficult to delete the personal information, tltworks shall cease the processing of the personal information, except for the storage and any necessary measure taken for security protection.

You can contact us via privacy@ltworks.co and request your data rights.

7. Security of Your Personal Information

We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. We will only keep your personal information for as long as necessary and in any event in relation to personal information collected by us on the Site we will only keep this personal information for one (1) year. For personal information collected via Google Analytics the following retention periods apply:

https://support.google.com/analytics/answer/7667196?hl=en

8. The Protection of Minors

The Site does not knowingly collect any personal information from minors. The personal information of any minor you provide shall be agreed by the minor’s parent or guardian in advance. Minor is defined in accordance with the laws applicable to this Privacy Policy of ltworks Website.

9. Use of Cookies and Other Tracking Technologies

ltworks may use cookies or other technology (collectively “Cookies”) to collect certain information about you when you are visiting the Site. Please read our Cookies Policy for more details.

10. Outside Sites and Linking

The Site may contain links and pointers to other sites on the Internet that are owned or operated by third party vendors and other third parties (the “Outside Sites“). ltworks is not responsible for the availability of, or the content located on or through, any Outside Site, including any webcasting or other form of transmission received from any Outside Sites. You should contact the site administrator or Webmaster for those Outside Sites if you have any concerns regarding such links or the content located on such Outside Sites. ltworks permits certain third party links to the home page of its Site, provided that ltworks is provided with notice of such links and does not thereafter object to such linking. ltworks a reserves the right to revoke unilaterally any consent that it may at any time give to any linkage, including linkages to the home page. The Outside Sites are being provided to you only as a convenience and any link or pointer contained on this Site does not imply endorsement of the Outside Sites.

11. Copyright

All Site content, design, text, graphics, images, logos, buttons, icons, interfaces, audio and video clips, and the selection and arrangements thereof are the exclusive property of ltworks, or its respective content providers, and are protected by Hong Kong SAR and international copyright laws. All software used on the Site is the property of ltworks or its respective software suppliers, and such software is protected by Hong Kong SAR and international copyright laws and other applicable laws and treaties. Users of this Site shall not transmit/post any information to this Site that infringes the copyright or other intellectual property rights of others.

12. Trademarks

All trademarks, service marks and trade names used on the Site (collectively the “Marks“) are solely owned by ltworks. The Marks may not be used in connection with any product or service that is not a product or service of ltworks or that is likely to cause confusion among customers, or that in any manner disparages or discredits ltworks.

13. Online Conduct

Any conduct by a person that in ltworks ‘s sole discretion restricts or inhibits any other person from using or enjoying the Site, is prohibited. You agree to use the Site only for lawful purposes and in accordance with that prohibition. You agree that you will not post on the Site or transmit any unlawful, harmful, threatening, abusive, harassing, defamatory, vulgar, obscene, sexually explicit, profane, hateful, racially, ethnically, or otherwise objectionable material of any kind, including, but not limited to, any material that encourages conduct that would constitute a criminal offense, give rise to civil liability or otherwise violate any applicable local, state, national, or international law.

14. Termination of Usage

ltworks may, without incurring any liability to you, terminate access by you or suspend any access to all or part of the Site, without notice, for any conduct that ltworks, in its sole discretion, believes is in violation of any applicable law or this Agreement, or is harmful to the interests of another user, a third-party, a merchant, a sponsor, a licensor, a service provider, or the Site.

Due to the rapidly evolving technologies on the Internet, we may occasionally update this policy. All revisions will be posted to this website www.ltworks.co

ltworks Cookies Policy

What are cookies?

Cookies are small text files that websites place on your device as you are browsing. They are processed and stored by your web browser, and can typically be read on your future visits.

In general, there are four types of cookies based on what purpose they serve.

  • Strictly necessary cookies – These cookies are essential for you to browse the website and use its features, such as accessing secure areas of the site.
  • Preferences cookies – also known as “functionality cookies,” these cookies allow a website to remember choices you have made in the past, like what language you prefer, what region you would like weather reports for, or what your user name and password are so you can automatically log in.
  • Statistics cookies – Also known as “performance cookies,” these cookies collect information about how you use a website, like which pages you visited and which links you clicked on. Their sole purpose is to improve website functions. This includes cookies from third-party analytics services as long as the cookies are for the exclusive use of the owner of the website visited.
  • Marketing cookies – These cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad.
What type of cookies does ltworks use?

ltworks only uses the following two type of cookies for the following purposes.

  • Preferences cookies- ltworks solely uses the preferences cookie to remember your set-up in the past in order to optimize the information presented to you.
  • Statistics cookies- ltworks also uses third party cookie of Google Analytics for purpose of helping us understand how the website is being used. Google Analytics collects first-party cookies, data related to the device/browser, IP address and on-site/app activities to measure and report statistics about user interactions. Google uses Google Analytics to provide the Google Analytics measurement service to ltworks. For more information about the Google Analytics cookies, please read here
Opt out

To opt out of our cookies used to remember the language you select when you visit our website, please find the guidance of managing and deleting cookies via www.allaboutcookies.org. To opt out of the third party cookie of Google Analytics, please click here

Our Partners

ltworks may partner with ad exchange platforms to provide advertising service. We encourage you to read the ad exchange partners’ privacy policy to understand their privacy practices and any options they provide you for exercising your data rights.

Please note that we make our best efforts to keep the list up to date by updating them on a regular basis.

By clicking “Accept”, you agree us to use Cookies to optimize the information presented to you, and analyze the traffic of our website. If you want to opt out of our cookies, please read our Cookies Policy for your guidance.