Privacy Policy

Update Date: September 4, 2025

Effective Date: September 4, 2025

Introduction

Beijing LLVISION Technology Co., Ltd. (hereinafter referred to as "LLVISION Technology" or "we") is committed to respecting and protecting the personal information shared with us by any user (hereinafter referred to as "user" or "you").

This Privacy Statement applies to all products and services provided by LLVISION Technology, including but not limited to all end point clients (hereinafter referred to as "LEION App" or "App"), such as the currently provided applications (App) LEION App developed based on the Android system and iOS system, the WeChat official account related to LEION App, LEION website, other products or services provided to you, and innovative R&D products and services provided from time to time. If you allow us to share information with third parties, you will also be subject to the third-party service terms and Privacy Policy.

This Privacy Statement describes the types of personal information we collect from you, how we use your personal information, how we share your personal information with third parties, how we store your personal information, the rights you have regarding your personal information, the transfer of your personal information, how we safeguard the security of your personal information, how we protect the personal information of juveniles, the update of the Privacy Statement, and how you can contact us. Before using our products and services, please carefully read and understand this Privacy Statement. If you have any questions about our personal information processing practices described in this Privacy Statement, please contact us through the means set out in Article 10 of this Privacy Statement so that we can respond to your specific questions. We will be happy to receive any feedback from you.

In the process of providing you with products or services, we will strictly comply with all applicable laws, regulations, and the principles required by the General Data Protection Regulation (hereinafter referred to as "GDPR") to process and protect your personal information: the principles of lawfulness, fairness, and transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, and confidentiality, etc.

Personal information in this Privacy Statement refers to information that, whether on its own or in combination with other relevant information, can be used to identify the personal identity of a natural person.

1. Types of personal information we collect and use

Given the wide variety of products and services we provide to you, you understand and agree that, for the purpose of continuously improving our products and services, we will introduce optimization features from time to time, which may increase or change the scope, purpose, and manner of collecting and using personal information. In this regard, we will separately notify you explicitly through means such as updating this Privacy Statement, pop-up windows, or inbox notifications, and provide you with the option to consent or not. You have the right to refuse to consent to this Privacy Statement (and its updates from time to time), but you also acknowledge and understand that once you refuse our collection and processing of your personal information in cases where it is necessary for the current or updated services or functions, we may be unable to provide you with the current or updated services and functions, or may not achieve the current or updated service effects, but your previously normally used basic functions will not be affected.

When you use our products and services, LLVISION Technology will collect some information about you and your device through electronic communication networks. We will only collect personal information that is relevant and necessary for the purpose for which you provide the information. The categories of personal information we collect are as follows:

l Basic personal information (email, account avatar, nickname, gender, etc.)

l Your mobile device information (IMEI number, MAC address, IP Address, logs and operation time, language setting preferences, operating system, Bluetooth information, etc.)

l Your AR glasses device information (model, device serial number, logs, operation time, etc.)

l Voice and text conversation content: Our service needs to collect the voice and text content of your conversations. Please note that when you use the aforementioned functions, although the voice and text content you input may contain your or others' personal information, we will not use this voice or text to identify any individual's identity. We will only conduct technical analysis by extracting strings to implement the input function. You can operate on your own to stop our collection of voice or text conversation content at any time. If you refuse to input the aforementioned information, or refuse our collection, viewing, or deletion of the voice content, text information, image information, etc. you input, you will not be able to use the aforementioned complete service. We promise to use this information only for providing this service and will not use it for any other purpose.

2. How We Collect and Use Personal Information

Generally, we collect, store, and use your personal information for the following purposes:

l Provide our products or services to you

l Provide after-sales/quality assurance services

l Answer customer inquiries

l Identify and improve defects in products and services

l Prevent fraud, criminal activities, and misuse of our products and services

l Statistical Analysis

Below, we will inform you one by one of the types of necessary personal information required for each function, and prompt you for the permissions to be authorized when you use specific functional scenarios.

2.1 Account Registration and Management

When you register for our App, we will collect your email address and the App account password you set yourself. The collection of the above information is to help you complete App registration and secure login; if you do not provide the above information, you may not be able to use our services properly.

In addition, to maintain your account basic information and enhance your service experience, you may choose to complete your account info, including uploading your avatar, setting your nickname, and filling in your birthday and gender; if you choose not to provide this information, it will not affect your use of our basic service functions.

2.2 Provides real-time speech transcription services for you

The microphone of your smart glasses device is set to off by default. We will only obtain the microphone permission of your glasses device after you actively click to enter the conversation or translation mode on the glasses screen, and collect conversation content through the microphone to provide you with real-time speech-to-text service; after you exit the conversation or translation mode, we will immediately stop collecting voice information.

Our speech-to-text feature is powered by Microsoft. When you use this service, the conversation content collected on your device will be directly transmitted to Microsoft and processed in accordance with Microsoft's Privacy Policy. You can view Microsoft's Privacy Policy atMicrosoft Privacy Statement - Microsoft Privacy. LLVISION Technology will not collect or store your voice content on our servers, but only obtain your mobile device storage permission for the purpose of allowing you to view conversation records within our App. Meanwhile, you can delete any historical conversation records you do not need or wish to keep at any time within our App.

2.3 Provide teleprompter services for you

Your smart glasses microphone is set to off by default. We will only obtain the microphone permission of your glasses device when you use the smart teleprompter feature, and collect speech content through the microphone to compare it with the teleprompter content so as to track your speech progress in real time. After you exit the smart teleprompter mode, we will immediately stop collecting voice information.

2.4 Provide AI Services for You

Your smart glasses microphone is set to off by default. We will only obtain your microphone permission after you wake up the AI, collect speech content through the microphone, convert the speech content from voice to text, and then have the AI understand and provide a response. We will immediately stop collecting voice information after you exit the AI.

Our AI service is technically supported by Microsoft. When you use this service, the voice content collected on your device will be transmitted to Microsoft and processed in accordance with Microsoft's Privacy Policy. You can view Microsoft's Privacy Policy at Microsoft Privacy Statement - Microsoft Privacy. LLVISION Technology will not collect or store your voice on our servers.

2.5 Problem Feedback and Participation in Our Operational Activities

If you participate in our operational and interactive activities, such as product feedback and questionnaires, we may collect and use the necessary information you voluntarily submit related to the activities or feedback, such as photos or videos you upload via the App, your contact information, etc.

2.6 Maintain the normal operation of services

When you use our products and services, to ensure your normal use of our services, maintain the normal operation of our services, improve and optimize your service experience, and safeguard the security of your account, we will collect and use necessary information related to your device (such as your device model, operating system, unique device identifier, login IP address, software version number, network access method, type, and status, etc.), and record your operation information (such as records of your search and view operations within our App, service fault information, etc.), which will be saved in the form of log files.

3. Sharing Your Personal Information with Third Parties

We will not sell any of your personal information to third parties. To help us provide you with the services described in this Privacy Statement, we may share your personal information with some of our business partners (such as our authorized distributors) when necessary to fulfill your orders or process some of your requests or complaints. LLVISION Technology will conduct due diligence and enter into contracts with these third parties to ensure that these third parties take appropriate measures to protect your information and strictly comply with applicable privacy laws.

Additionally, as stated in the second part of this Privacy Statement, our products and services include some technical service support provided by third-party service providers in the form of SDK or API. We have no control over how these third parties use the personal information they collect from you, nor are we responsible for it. Therefore, we strongly recommend that you take the time to read their privacy statements while reading this Privacy Statement.

We also use Cloud as a Service provided by Microsoft to conduct storage and processing activities for data that includes your personal information.

If we are legally required to transfer certain personal information of yours, such information may also be transferred to other third parties (such as public institutions).

4. Store your personal information

Generally speaking, we will store your personal information within the necessary period required for the purpose of collecting personal information described inthis Privacy Statementto achievethe purpose of collecting personal information. We may also retain your personal information to fulfill our relevant legal obligations. When the purpose for which we collect personal information has been achieved, or we confirm that you have the right to delete your personal information, or we stop providing products or services related to the collection and processing of your personal information, we will destroy your personal information by ceasing to store, deleting, or anonymizing it.

5. Your rights regarding personal information

Depending on the applicable laws and regulations of your country or region, you may have multiple rights regarding the personal information we hold about you, such as the right to request access, correction, and deletion of your personal information. To exercise these rights, we may ask you to provide necessary information to verify your identity and, in some cases, assist us in searching for your personal profile.

5.1 Right to Withdraw Consent

If you have consented to the processing of personal information for a specific activity, you may withdraw this consent at any time. For example, you can revoke your authorization for access to your phone's photo album by going to "Settings - Privacy - Photos" on your mobile device. You can also withdraw all authorizations for our continued collection and processing of your personal information by canceling your account. You should understand that once you withdraw your authorization, we will be unable to continue providing you with the specific functions and services corresponding to the withdrawn authorization. However, your decision to withdraw authorization will not affect the personal information processing that has been carried out based on your previous authorization.

5.2 Access to Your Personal Information

You have the right to access at any time the personal information we hold about you. The specific content you can access includes the categories of personal information we process, the purposes of processing, the source channels of personal information (if we obtained your personal information indirectly from a third party), and the third-party recipients to whom your personal information has been disclosed (if any), etc.

You can view most of your personal information we have collected in our App. You may also exercise this right by contacting us, and we will provide you with a copy of your personal information free of charge.

5.3 Correct Your Personal Information

You may request us to correct your information. We will take appropriate steps to ensure that the personal information we hold and process about you is up-to-date, accurate, complete, and relevant. You can directly modify most of the personal information you have filled out in the App. You may also exercise this right by contacting us.

5.4 Delete your personal information

Subject to relevant legal requirements, you have the right to request the deletion of your personal information. Generally, you may exercise this right when we no longer need to process your personal information or when your personal information has been illegally processed. In response to your legitimate request for deleting personal information, we will take all reasonable and feasible steps to delete the relevant personal information.

You may cancel your previously registered account at any time. You can cancel your account by yourself through the following steps in the LEION App: "Settings" - "Account Security" - "Cancel Account". If you are unable to cancel your account through the aforementioned method, you may request to cancel your account via the contact information specified in Article 10 of this Privacy Statement. After you voluntarily cancel your account, unless otherwise required by applicable laws and regulations, we will stop providing you with products and/or services, and delete your personal information or anonymize it.

5.5 Right to Complain to Regulatory Authorities

LLVISION Technology highly values and takes seriously your privacy concerns. However, if you are not satisfied with our response or handling, you have the right to lodge a complaint with the relevant data protection regulatory authority.

Additionally, depending on the laws and regulations of your country or region, you may also have the right to be free from the impact of fully automated decision-making (including user portraits) that may have a significant impact on you. We currently do not make any decisions about you in this way, but if the situation changes, we will timely update this Privacy Statement and notify you by means of an announcement.

6. How your personal information is transferred globally

We may share certain personal information with our third-party service providers, and as a result, your information may be transferred to countries or regions outside your own. The jurisdictions where these entities are located may not enforce the same personal information protection standards as your jurisdiction. However, this does not alter or affect our commitment to complying with this Privacy Statement and protecting your personal information. If we may need to transfer your personal information outside your jurisdiction, whether to our third-party providers, business partners, or affiliated companies, we will do so in accordance with applicable laws.

Currently, the specific details of the transfer of your personal information abroad are as follows:

Types of personal information transferred abroad: All your personal information that we collect and process (excluding the voice recorded by you using our devices)

Country to which personal information is transferred: Singapore.

Compliance of Transfer: We will ensure that during the process of information transfer, we simultaneously meet the legal requirements of your country or region, as well as the relevant requirements and regulations of Singapore's Personal Data Protection Act (hereinafter referred to as "PDPA"). The overseas recipient will fully comply with the data protection obligations stipulated in PDPA and assume protection responsibilities that are substantially equivalent to those required by PDPA, and will take reasonable security measures to protect your personal information against risks such as unauthorized access, collection, use, disclosure, copying, modification, etc. When retaining your personal information no longer aligns with the initial purpose of collection and is no longer necessary for business or legal purposes, the overseas recipient will cease retaining such data or conduct anonymization.

Time and method of transfer: Using our AR glasses products and App services requires network connectivity for operation.

Overseas recipient and its contact information:Cloud Computing Services | Microsoft Azure

Reasons for overseas recipients to obtain personal information: Cloud as a Service providers commissioned by us to provide data storage and processing services.

7. How do we safeguard your personal information security?

The security of your personal information is of utmost importance to us. We will do our best to take appropriate technical and organizational security measures in line with industry standards to protect your information from leakage, loss, misuse, or tampering. We implement security measures such as the following:

l Your personal information will only be accessed by specific personnel within our company for specific processing purposes. We also implement strict management of employees or outsourced personnel who may have access to your information, including but not limited to implementing different access controls based on job positions, signing Non Disclosure Agreements with them, and monitoring their operations. We will provide corresponding security measures in accordance with Prior Art to protect your information and provide reasonable security safeguards, and we will do our best to ensure that your information is not leaked, damaged, or lost;

l Your personal information is only transmitted in encrypted form and stored encrypted. The server systems where we store user personal information are all operating systems that have been securely fortified. We will conduct account audits and monitoring of server operations. If we discover a server operating system with security issues announced externally, we will immediately upgrade the server security to ensure the security of all our server systems and applications;

l Emergency response and reporting mechanisms for data and personal information breaches. We have developed an emergency response plan for information security incidents and allocated sufficient resources to ensure its implementation. We conduct annual training on the emergency response plan and emergency incident drills. If our physical, technical, or administrative safeguards are unfortunately breached, we will promptly activate the emergency response plan to prevent the security incident from escalating, report it to the national competent authorities in accordance with the requirements of laws and regulations, and promptly inform you of the basic situation of the security incident, possible impacts, measures already taken or to be taken, etc., through reasonable and effective means such as push notifications and announcements.

However, please be aware that the Internet is not an absolutely secure environment. Despite the aforementioned security measures, please also understand that there is no "perfect security measure" on information networks. Therefore, please properly protect your personal information and only provide it to others when necessary. If you find that your personal information has been leaked, especially if your account and password have been compromised, please contact us immediately so that we can take appropriate measures.

8. How do we protect the personal information of Juveniles?

Our products and services are primarily targeted at adults. Juveniles should obtain the consent of their guardians before using our products and services. If you are a juvenile (under 18 years of age or under the age required by the laws of your place of residence to use the LEION App), please carefully read this policy under the accompaniment of your parents or other guardians before using the LEION App and other products and services provided by us, and use our services or provide information to us only after obtaining the consent of your parents or other guardians. We protect the personal information of juveniles in accordance with relevant national laws and regulations, and will only collect, use, or publicly disclose the personal information of juveniles when permitted by laws and regulations, with the affirmative consent of guardians, or when necessary to protect your rights and interests. If you are the parent or other guardian of a juvenile, please pay attention to whether the juvenile under your guardianship uses our services after obtaining your authorized consent. We will protect the confidentiality and security of juvenile user information in accordance with applicable laws and regulations and the provisions of this policy. At the same time, we have established strict rules for the collection and use of juvenile information to protect the security of juvenile personal information. If you have any questions about the personal information of the juvenile under your guardianship, please contact us through the contact information in Article 10 of this Privacy Statement. If we discover that we have collected the personal information of a juvenile without prior verifiable guardian consent, we will delete the relevant data as soon as possible or take other appropriate measures in accordance with applicable laws.

For the personal information of children under 14 years old that may be involved, we will further take the following measures to ensure its protection:

Regarding the collected personal information of children, in addition to complying with the provisions of this Policy regarding users' personal information, we will also adhere to the principles of justifiability and necessity, informed consent, clear purpose, security assurance, and lawful utilization, strictly follow the requirements of laws and regulations for storage, use, and disclosure, and will not exceed the period necessary to achieve the purpose of collection and use. After the expiration, we will delete or anonymize the personal information of children.

When you, as a guardian, choose to use our services on behalf of a child under your guardianship, we may need to collect the personal information of the child under your guardianship from you, which is necessary for us to provide you with relevant services. In specific services where we need to collect the child's personal information from you, we will obtain your express consent in advance and inform you of the purpose and use of the collection. You have the right to choose whether to provide such information, but in most cases, if you do not provide the aforementioned information, you will not be able to enjoy the relevant services we provide. As a guardian, you should properly fulfill your guardianship duties and protect the security of the child's personal information. If the child himself/herself needs to register or use our services, you should properly guide and supervise him/her.

Children or their guardians have the right to access and correct children's personal information at any time, and may also submit requests for correction and deletion to us. If you have any comments, suggestions, complaints, or reports regarding matters related to children's personal information, please contact us through the means described in Article 10 of this Policy, and we will delete the relevant data as requested. Additionally, if we discover that children's personal information has been collected without prior verifiable parental consent, we will also endeavor to delete the relevant data as soon as possible.

9. Updates to the Privacy Statement

This Privacy Policy will be updated, revised, or amended from time to time based on the actual handling of personal information. If there are any updates, changes, or revisions to the terms of this Privacy Policy, we will provide you with the revised policy through in-app push notifications. If you do not agree to the amendments to this Agreement, please immediately stop using the LEIONA App and/or other products and services provided by us; if you choose to continue accessing or using the LEIONA App and/or other products and services provided by us after the amendment of this Policy, it indicates that you agree to be bound by the updated Privacy Policy and its related policies.

It should be specifically noted that this Policy does not apply to services provided to you by other third parties, such as third-party services or websites you access through the LEION App. We will make every effort to urge these third parties to protect your personal information during our cooperation with them, but you understand that these services are provided to you independently by third parties, and third parties will be solely responsible for handling your personal information in accordance with their Privacy Policy or User Agreement.

10. Contact Us

We have appointed a dedicated person in charge of personal information protection, who is responsible for handling all matters related to users' personal information that may be involved in the products and services provided by LLVISION Technology. If you wish to exercise any of your personal information rights by directly contacting us, or if you have any questions about the content of this Privacy Policy, you may contact us in the following ways:

Email: service@llvision.com

Address: Building 8, Courtyard 10, Kegu 1st Street, Beijing Economic-Technological Development Zone, Beijing, Zip Code: 101111.

11. EEA + Supplementary Privacy Statement

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland (collectively referred to as "EEA+"), the European Union's General Data Protection Regulation and local data protection laws (as applicable) apply when we process your personal data. If you are located in the United Kingdom, the United Kingdom's General Data Protection Regulation applies when we process your personal data. References to "GDPR" refer to the General Data Protection Regulation applicable to your country. If you are located in Switzerland, the Swiss Federal Data Protection Act (FDPA) applies when we process your personal data, as applicable to the FDPA. In the event of any inconsistency between this article and other provisions of this Privacy Statement, the provisions of this article shall prevail.

In the European Economic Area, Switzerland, and the United Kingdom, you have the following rights, subject to the conditions of the General Data Protection Regulation and/or local data protection laws:

a. Object to our processing of your personal data on grounds relating to your particular situation. This includes the right to object to our use of your personal data for direct marketing (also known as mass marketing under Swiss law), as well as the right to object to our processing of your personal data when performing tasks in the public interest or pursuing our legitimate interests or those of a third party. If we process your personal data on the basis of our legitimate interests or those of a third party, or on the basis of public interest, you may object to such processing, and we will cease processing your personal data, unless the processing is based on compelling legitimate grounds or required by law. When we use your personal data for direct marketing of our own products and services, you may object at any time and opt out of receiving future marketing communications by using the unsubscribe link in these communications or other means.

b. Obtain confirmation from us as to whether your personal data is being processed, and in such case, request access to details about how we process your personal data and a copy of the personal data.

c. Obtain from us the correction of your inaccurate personal data.

d. Request that we delete your personal data, provided that such data is not necessary for the purposes required by law or for security and integrity purposes.

e. Request to restrict the processing of your personal data, in which case it will be marked and used by us only for specific purposes.

f. Receive personal data you provide to us in a structured, commonly used, and machine-readable format, and you have the right to transfer personal data to another entity without our hindrance.

g. Withdraw your consent at any time. This will not affect the lawfulness of our use of your personal data prior to your withdrawal.

h. File a complaint with the regulatory authority.

i. In certain jurisdictions (such as France and Portugal), you also have the right to provide us with instructions regarding the handling of your personal data after your death.

To submit a request to exercise your privacy rights, you may contact us through the contact information set out in Article 10 of this Privacy Statement.