Effective Date: August 10, 2026
Last Updated: August 10, 2026
This Privacy and Cookie Policy ("Policy") explains how Lemo IoT International Limited ("Lemo", "we", "us", or "our") collects, uses, discloses, stores, and protects personal information when you visit our official website at https://lemoglobal.com (the "Website").
Please read this Policy carefully before using the Website. By accessing or using the Website, you acknowledge that you have read and understood this Policy and agree to the practices described herein. If you do not agree with this Policy, please discontinue use of the Website.
1. Information We Collect
Lemo does not require you to create an account or log in to use the Website. The personal information we collect is limited to what is necessary to operate the Website, ensure its security, and respond to your inquiries. We adhere to the principle of data minimization: we collect only the personal information that is adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
1.1 Information You Provide Voluntarily
- Contact and inquiry forms: If you submit a contact or inquiry form, we collect your name, email address, company name, and the content of your message.
- Business correspondence: Information you provide when you communicate with us by email or other channels.
1.2 Information Collected Automatically
When you visit the Website, we automatically collect certain technical information, including:
- IP address (truncated where feasible)
- Browser type and version
- Device type and operating system
- Pages visited, time of visit, and time spent
- Referring URL
- Approximate location (country/region, derived from IP)
This information is collected through server logs and the strictly necessary cookies described in Section 2.
2. Cookies and Similar Technologies
2.1 What Are Cookies
Cookies are small text files placed on your device when you visit a website. They allow the website to recognize your device and remember information about your visit. This section describes how we use cookies and how you can manage them.
2.2 How We Use Cookies
Lemo uses only a minimal set of cookies. Because the Website does not require login and does not perform behavioral tracking, we do not deploy advertising or marketing cookies, and we do not sell information derived from cookies. The cookies we use are limited to those strictly necessary for the Website to function.
Functional Cookies: Lemo does not currently deploy functional cookies. If we add functional cookies in the future (e.g., to remember language preference), we will update this Policy and obtain your consent where required by applicable law.
Analytics Cookies: Lemo does not currently deploy analytics cookies (e.g., Google Analytics). If we add analytics in the future, we will update this Policy and obtain your consent where required.
Marketing and Advertising Cookies: Lemo does not deploy marketing or advertising cookies.
2.3 Managing and Disabling Cookies
You can manage or disable cookies through your browser settings:
- Google Chrome: Settings → Privacy and Security → Cookies and other site data
- Safari: Preferences → Privacy → Cookies and website data
- Microsoft Edge: Settings → Cookies and site permissions
- Mozilla Firefox: Preferences → Privacy & Security → Cookies and Site Data
Disabling strictly necessary cookies may affect the functionality of the Website. For more information on managing cookies in other browsers, please consult your browser provider's documentation.
2.4 Cookie Consent
When you first visit the Website, we display a cookie banner. By continuing to browse the Website, you acknowledge our use of strictly necessary cookies as described in this Policy. Because we only use strictly necessary cookies, separate opt-in consent for non-essential cookies is not required. You may clear your cookie preferences at any time by clearing cookies in your browser settings or by contacting us as described in Section 11.
3. Legal Basis and Purposes of Processing
We process personal information for the following purposes, on the corresponding legal bases:
| Purpose | Legal Basis |
|---|---|
| Operating, maintaining, and securing the Website | Legitimate interests |
| Responding to your inquiries and providing requested information | Consent / legitimate interests |
| Preventing fraud, abuse, and security threats | Legal obligation / legitimate interests |
| Analyzing usage patterns to improve Website performance | Legitimate interests |
| Meeting legal and regulatory obligations | Legal obligation |
Where consent is the basis for processing, you may withdraw your consent at any time without affecting the lawfulness of processing carried out before the withdrawal. To withdraw consent, please contact us using the details in Section 11.
4. Sharing and Disclosure of Personal Information
We do not sell, rent, or trade your personal information. We may share personal information in the following circumstances:
- Service providers: We engage third-party service providers to assist us in operating the Website (e.g., hosting providers, email service providers). These providers are bound by contractual obligations of confidentiality and security and are permitted to process personal information only as instructed by Lemo.
- Legal compliance: We may disclose personal information where required by applicable law, regulation, or legal process, or in response to lawful requests from public authorities.
- Business transfers: In connection with a merger, acquisition, reorganization, or sale of assets, we may transfer personal information, subject to the protections of this Policy and applicable law.
We require all service providers to maintain security standards comparable to our own and to process personal information only for the purposes for which it was shared.
5. Cross-Border Data Transfer and Storage
5.1 Storage Location
We store personal information collected through the Website on servers located in Singapore, hosted by our group entities. The storage infrastructure complies with the data security requirements of the People's Republic of China.
5.2 Cross-Border Transfer
Because Lemo is registered in Hong Kong and serves users worldwide, your personal information may be transferred from your jurisdiction to China for storage and processing.
We undertake cross-border transfers in accordance with applicable law, on the following bases:
- User consent: Where required by the law of your jurisdiction, we rely on your consent to the cross-border transfer of your personal information, as described in this Policy. You may withdraw this consent at any time.
- Comparable protection: We ensure that recipients of personal information in China are bound by contractual and organizational measures that provide a level of protection comparable to that required under the law of your home jurisdiction.
5.3 Retention of Transferred Data
Personal information transferred across borders is retained in accordance with Section 6 below.
6. Data Retention
We retain personal information only for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required by applicable law:
| Data Category | Retention Period |
|---|---|
| Contact form and inquiry submissions | 2 years from submission |
| Business correspondence | 2 years from last interaction |
| Server log data | 12 months |
Upon expiration of the applicable retention period, we delete or anonymize the personal information. Where deletion is not technically feasible, we will isolate the information from further processing until deletion is possible.
7. Security Measures
We implement industry-standard technical and organizational measures to protect personal information against unauthorized access, disclosure, alteration, loss, or destruction:
- Encryption in transit: Sensitive data is encrypted using TLS during transmission.
- Access control: Access to personal information is restricted to authorized personnel on a need-to-know basis, with access logs maintained.
- Security monitoring: We monitor systems for security threats and malicious activity.
- Personnel training: Our personnel receive regular privacy and security awareness training.
- Incident response: We maintain an incident response plan. In the event of a personal data breach, we will notify affected users and the relevant supervisory authorities in accordance with the requirements of applicable law, generally without undue delay.
No method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information using commercially acceptable means, we cannot guarantee absolute security.
8. Your Rights Regarding Personal Information
You have certain rights regarding your personal information. To exercise any of these rights, please contact us using the details in Section 11. We will verify your identity before processing your request.
8.1 General Rights (All Markets)
- Right of access: Request a copy of the personal information we hold about you.
- Right to correction: Request correction of inaccurate or incomplete personal information.
- Right to deletion: Request deletion of your personal information, subject to legal retention obligations.
- Right to withdraw consent: Withdraw consent previously given where processing is based on consent.
- Right to object: Object to processing based on legitimate interests or for direct marketing.
- Right to restrict processing: Request restriction of processing in certain circumstances (e.g., while a correction request is being verified).
- Right to data portability: Receive your personal information in a structured, machine-readable format, where applicable.
- Automated decision-making: We do not engage in solely automated decision-making that produces legal or similarly significant effects.
8.2 California Privacy Rights (CCPA/CPRA)
If you are a California resident, you have additional rights under the CCPA/CPRA:
- Right to know: The categories and specific pieces of personal information we have collected, sold, shared, or disclosed about you, and the purposes for which they were used.
- Right to delete: Request deletion of personal information we collected from you, subject to exceptions.
- Right to opt out of sale or sharing: The right to opt out of the "sale" or "sharing" of personal information for cross-context behavioral advertising. Lemo does not sell or share personal information for cross-context behavioral advertising, so no opt-out is necessary.
- Right to limit use of sensitive personal information: The right to limit the use of your sensitive personal information to that necessary for performing the services or providing the goods reasonably expected.
- Right to non-discrimination: Equal service and pricing, whether or not you exercise your privacy rights.
"Do Not Track" signals: Our Website does not currently respond to "Do Not Track" signals transmitted by browsers, as there is no consistent industry standard for processing such signals. However, our privacy practices remain the same regardless of DNT status. Because we do not sell personal information or engage in cross-context behavioral advertising, your privacy is not affected by this choice. We will continue to monitor developments in this area and update this Policy if our practices change.
To exercise your California privacy rights, submit a verifiable request via the contact methods in Section 11.
8.3 Response Time
We will respond to your rights requests within the period required by applicable law (generally 30 days from receipt of a verified request). If we need additional time, we will inform you of the reason and the expected response timeframe.
9. Information About Minors
The Website is not directed at, and is not intended for use by, individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe a minor has provided us with personal information, please contact us using the details in Section 11, and we will take steps to delete such information as soon as practicable.
10. Updates to This Policy
We may update this Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. When we make changes:
- We will update the "Effective Date" and "Last Updated" fields at the top of this Policy.
- For non-material changes, we will update the Website without separate notice.
- For material changes (e.g., changes to the purposes of processing, categories of information collected, sharing arrangements, or your rights), we will provide prominent notice on the Website (such as a pop-up or banner) and, where required, seek your renewed consent.
Continued use of the Website after a policy update constitutes acceptance of the revised Policy, except where renewed consent is required by applicable law.
11. Contact Us
If you have any questions, requests, or concerns regarding this Policy or your personal information, please contact our Data Protection Officer:
Lemo IoT International Limited
Attn: Data Protection Officer
Email: akeelah.wang@lemobar.com
Phone: +86 4008593566
Postal address: Room A5, 7/F, Astoria Building, No.34 Ashley Road, Tsim Sha Tsui, Kowloon, Hong Kong
We aim to respond to all inquiries within 15 business days. Where a statutory deadline applies (e.g., 30 days under CCPA/CPRA or Thai PDPA for data subject requests), we will respond within that statutory period.
End of Policy