Latsen Technology Ltd.

Date: March 23, 2023

Your trust is of great importance to us. We deeply understand the importance of personal information to you and will take corresponding security measures in accordance with laws and regulations and strive to protect your personal information to keep it secure and under control. Therefore, we provide Pawfit products and services under Latsen Technology Ltd. ("we" or "us") and formulates this Privacy Policy (the "Policy", which term includes any applicable country specific addendums) by reminding you that:

This Policy is applicable to Pawfit products and services, including Pawfit official website (domain name: www.pawfit.com), Pawfit web version and Pawfit App, intelligent hardware under the brand of Pawfit and the integration of certain Pawfit features/services as a third-party service in intelligent hardware, software and/or other third parties.

Please note that depending on the country where you are located while using the Pawfit products, there may be certain country specific addendums that may apply to you that form an integral part of this Privacy Policy.

Prior to the use of Pawfit products or services, please carefully read and thoroughly understand this Policy and confirm that you have fully understood and agreed to this Policy before using relevant products or services. Your use of Pawfit products or services shall be deemed as you have fully understood and agreed to this Policy. If you have any questions, comments or suggestions on the content of this Policy, please contact us at the following address: Pawfit Team, Latsen Technology Ltd., Unit 19A, The Matchworks, Speke Road, Liverpool, L19 2RF, United Kingdom

We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register for the Services. If you are under 13, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 may provide any personal information to us or on the Services. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at the following address: Pawfit Team, Latsen Technology Ltd., Unit 19A, The Matchworks, Speke Road, Liverpool, L19 2RF, United Kingdom

Definitions

Pawfit: is a multi-terminal platform and client developed and operated by Pawfit Service Providers under Latsen Technology LTD. It is designed to provide petcare services for pet lovers. It includes Pawfit official website (domain name: www.pawfit.com), Pawfit web version and Pawfit App, intelligent hardware under the brand of Pawfit and services provided by integration of certain Pawfit features/services as a third-party service in software and/or other third parties.

Pawfit Service Provider: means Latsen Technology LTD who conduct research over, develop and provide Pawfit products and services.

Personal Information: means all information electronically or otherwise recorded that can be used to identify a natural person or reflect his/her activities, whether on its own or in combination with other information.

Personal Information Deletion: means the removal of Personal Information from the systems as involved in daily business operations to keep such information irretrievable and inaccessible.

Policy

This part will help you understand the followings:

I. What personal information we collet and how we use it.
II. How we use Cookie.
III. How we share, transfer and disclose your Personal Information.
IV. How we protect your Personal Information.
V. How we store Personal Information.
VI. How we process Personal Information of minors.
VII. How to request Personal Information deletion.
VIII. How we update this Policy.
IX. How to contact us.

I. What personal information we collet and how we use it

(I) What personal information we collect

We collect and use your Personal Information for the purposes as stated below:

1. Help you become a Pawfit user

To become a Pawfit user, you are required to provide your name, email address to create a Pawfit account and password, so that we can provide you with membership services, including activating and using your Pawfit tracker. You can also choose to create your Pawfit account via your Facebook or Apple ID account. If you choose to sign up by using your Facebook or Apple ID account, your Facebook or Apple ID, name, email address, and avatar will be used. You are not required to register to be our member or provide the above information if you only use such basic services as browsing and searching the official website of Pawfit for services and the introduction thereof.

After activating your Pawfit account and becoming a Pawfit user, you may modify your Personal Information such as name, avatar and password via the Pawfit app.

2. Provide you with products or services

1)Information provided by you to us

We receive and store information you enter on our Website and Pawfit app, or provide to us in any other way, including, without limitation, through use of the Pawfit products or services. The types of Personal Information collected in this fashion may include, but is not necessarily limited to, your (and your pet's) name, your email address, optional contact information including phone number and address to set up the audio ID, optional WiFi access points, voluntarily WiFi password used in certain Pawfit models, any content you post to your profile or through the Website, and any other information necessary for us to provide the Services. Your Pawfit account password is received and stored through one-way encryption which means that we do not actually store and know your original password. You can choose not to provide us with certain information, but then you may not be able to take advantage of many of our special features. The Personal Information you provide is used for such purposes as answering questions and providing troubleshooting, improving the user experience of the App, product and Website, customizing the advertising and content you and other users and prospective users see, and communicating with you about Latsen's products and services, including specials and new features.

2) Information collected by us when you use services

We receive and store certain types of information whenever you interact with our website, mobile App, product or use our Services. Latsen automatically receives and records information on our server logs from your browser, including your IP address, cookie information, browser and/or mobile device information, operating system, timestamps, the specific Pawfit pages you request, your pet's locations and activity data, location of your mobile device when setting up the home WiFis, using the location share feature and Bluetooth tracking, WiFi access points that your Pawfit tracker detects, and any other information necessary for us to provide the Services. You can choose not to grant our website, mobile app to access certain information, but then you may not be able to take advantage of many of our features.

Generally, our Services automatically collect usage information, such as the number and frequency of visitors to our website and how those users use its various components, including, without limitation, pet's activity data from the product. Latsen never discloses aggregate information to a partner in a manner that would identify you or your pet personally, except as may be required to provide you with features and functionalities selected by you and provided through the products and Services of our integration partners.

3) Information collected by us when you use customized services

In order to provide you with better, more customized services, such as providing more customized services but with consistent experience in different service terminals or devices, and with input recommendations, customers service reception or information push that better meet your needs, and to understand product fitness, and identify abnormalities of accounts, we will collect information relating to your use of services, including device information, log, service use information.

Log: When you use our website, we will automatically collect detailed information relating to your use of our services and save them as network logs, such as your IP addresses, types of browsers, languages, visit dates and times, length of visits, information of software and hardware features, Pawfit Cookies, etc. When you use our product, we will automatically collect your pet's locations, activity data, environmental temperature and alerts whenever they become available.

3. Provide safeguards for you

To prevent, identify and investigate in any fraud, infringement, dangerous act, illegal act or act in violation of our agreements, policies or rules, we may collect or integrate your user information, service use information, device information, log information with your authorization or as required by laws.

4. Other purposes

When we collect your information for any other specific purpose not specified herein, we will obtain your consent in advance.

The purpose for Latsen Technology Ltd. to collect and use the aforesaid information is to better operate the Pawfit products and services (including but not limited to provide customized service to you), and we will notify you of all new functions and new services with a notice on our website, or via email.

If we stop operating Pawfit products or services, we will timely stop collecting your Personal Information, send you a notice thereof on a personal basis or in the form of announcement, and delete or anonymize the Personal Information held by us.

(II) How we use your information

We collect your information for the purpose of providing you with services and improving the service quality. Therefore, we will use your information for the following purposes:

1. Provide you with Pawfit products or services you intend to use, and maintain, improve and optimize these services and experience with these services;

2. To prevent, identify and investigate in any fraud, infringement, dangerous act, illegal act or act in violation of our agreements, policies or rules, and protect your, our, the public's lawful interests, we may use or integrate your user information, service use information, device information, log information with your authorization or as required by laws.

3. We may process your information or combine your information with information from other services in order to provide more customized service to you, such as to recommend to you any contents which you may be interested in, including but not limited to send product and service information to you, or display personalized third-party promotional information to you through the system.

4. Any other purpose as permitted by you.

II. How we use Cookie

To provide you with better user experience, when you use Pawfit products or services, we may collect and store data relevant with your visit to Pawfit service by employing various technologies. In this way, when you visit or revisit Pawfit service, we will be able to identify you and provide better and more services to you through analyzing the data. This will include verifying your identity through small data files, so that we will be able to understand your habits and help you avoid repeated input of account information or help assess the security of your account. These data files may be Cookie, Flash Cookie or other local storage provided by your browser or relevant applications (collectively, “Cookie”).

Please understand that some of our services are only available through use of “Cookie”. If permitted by your browser or additional browser services, you may change your acceptance level to Cookie or reject Cookie of Pawfit, but under certain circumstances, such rejection may render you unable to use certain functions of Pawfit which rely on Cookie.

Web Beacon are sometimes included in web pages, which may help a website to calculate the number of users who browse the web pages or access certain Cookies. We may use Web Beacon to collect information on your browsing of Pawfit's web pages, such as the specific Pawfit web page address you are visiting, the reference page address you previously visited, the duration of your stay on a Pawfit web page, your browsing environment and display settings.

III. How we share, transfer and disclose your Personal Information

(I) Share

We will not share your Personal Information with companies, organizations or individuals other than Pawfit Service Providers, except in the following circumstances:

1. Sharing with explicit consent: We will share your Personal Information with other parties with your explicit consent;

2. Sharing as required by laws: We may release your Personal Information when we believe in good faith that such release is necessary to comply with the law, regulation, litigation, dispute resolution, or by administrative or judicial authority in accordance with laws;

3. The products and services you request may only be provided with disclosure of your information;

4. When a complaint is made by others against you of infringing upon intellectual property rights or other lawful interests, we may disclose your information as necessary to the complainer for settlement of complaint with your awareness;

5. Sharing with authorized partners: Certain services of ours will be jointly provided together with our authorized partners solely for the purposes stated herein. We may share certain Personal Information of yours with our partners to provide better customer service and user experience with your consent. For example, when you purchase products on the website online, we may have to share your Personal Information with logistics service providers to arrange delivery of such products, or we may have to share your personal information to arrange with our partner to provide service. We will only share your Personal Information for lawful, proper, necessary, specific and explicit purpose to the extent required for providing the services. Our partners have no right to use the shared Personal Information for any other purpose irrelevant with products or services.

(II) Transfer

We will not transfer your Personal Information to any company, organization or individual, except in the following circumstances:

1. Transfer with explicit consent: We will transfer your Personal Information to other parties with your explicit consent;

2. In case of any acquisition, merger or insolvency liquidation, or other circumstances involving merger, acquisition or insolvency liquidation, of Pawfit Service Providers, if transfer of Personal Information is involved, we will require the new company, organization or individual in possession of your Personal Information to continue to be bound by this Policy, or we will require such company, organization and individual to obtain your authorization and consent again.

(III) Public disclosure

We will disclose your Personal Information to the public only under the following circumstances:

1. We may disclose your Personal Information to the public with your explicit consent or at your voluntary option;

2. If we believe in good faith that you have violated laws and regulations, or have a material breach of the agreements with or regulations of Pawfit, or we intend to protect Pawfit's and the general public from damages to their personal and property safety, we may disclose your Personal Information in accordance with laws and regulations, or the agreements with and regulations of Pawfit after obtaining your consent, including the relevant violation and measures taken by Pawfit against you.

IV. How we protect your Personal Information

We will take various precautions to protect your Personal Information to safeguard your Personal Information from loss, misappropriation and misuse, and from being accessed, disclosed, modified or destroyed without permission. To ensure the safety of your Personal Information, we have established strict information security provisions and procedures to ensure your Personal Information is stored securely.

Your Pawfit account Personal Information is protected by a password for your privacy and security. Your password is stored through one-way encryption, which means that we do not know your original password. You need to ensure that there is no unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer (or other device) and browser by signing off after you have finished accessing your account.

We will take reasonable and practical measures to avoid collecting irrelevant Personal Information to the maximum extent. We will retain your Personal Information only for the period necessary to achieve the purposes set forth in this Policy, unless it is necessary to prolong the retention period or permitted by law.

Upon occurrence of any Personal Information security incident, we will, in accordance with the requirements of laws and regulations, notify you of the basic information and possible influence of such security incident, handling measures we have taken or will take, suggestions on how you may prevent and reduce risks on your own, and remedies to be taken for you. We will notify you of the relevant information of such incident through email, push notification. If it is difficult to notify each Personal Information subject one by one, we will publish announcement in a reasonable and effective manner, i.e. our website. In addition, we will also report the handling of Personal Information security incident according to the requirements of regulatory authorities.

Given the fact that Internet environment is not completely secure, although we have those security measures in place, please bear in mind that there is no “perfect security measure” on the Internet, and we will use our best efforts to ensure the security of your information.

V. How we store Personal Information

Principally, your Personal Information collected by our operating of Pawfit will be stored at our servers locate within Europe and North America.

VI. How we process Personal Information of minors

We attach great importance to the protection of information of minors. If you are a minor, we suggest that you ask your guardian to read this Policy carefully, and use our services and/or provide us with information with the consent of your guardian. When you register for and use the products and services provided by Pawfit, we tacitly believe that you have obtained the consent of your guardian, and we will protect the Personal Information of minors in accordance with relevant national laws and regulations and this Policy.

VII. How to request Personal Information deletion

We will anonymize or delete your Personal Information within one hundred and eighty calendar days or pursuant to applicable laws and regulations should you inform us by writing to following address deregister your individual Pawfit account. Address: Pawfit Team, Latsen Technology LTD., Unit 19A, The Matchworks, Speke Road, Liverpool, L19 2RF, United Kingdom.

Alternatively you can choose to delete your account including all Personal Information via the mobile app. To do that please log in to your Pawfit app account, go to ‘Profile>User profile>User settings>About Pawfit>Account control>Delete account’. Deleting an account will erase all Personal Information and tracking data with it permanently. This operation cannot be undone.

VIII. How we update this Policy

Our Policy may change from time to time. Without your explicit consent, we will not reduce and/or restrict the rights you are entitled to under this Policy. We will publish any change to this Policy on Pawfit official website at www.pawfit.com and, if changes are significant, prominent, we will also provide a more prominent notice (including using Pawfit to collect opinions and make publicity, or by providing you notice with popup window within Pawfit official website).

Our Policy may change from time to time. Without your explicit consent, we will not reduce and/or restrict the rights you are entitled to under this Policy. We will publish any change to this Policy on Pawfit official website at www.pawfit.com and, if changes are significant, prominent, we will also provide a more prominent notice (including using Pawfit to collect opinions and make publicity, or by providing you notice with popup window within Pawfit official website).

Significant changes to this Policy are included but not limited to the follows:

1. Our service pattern changes greatly, such as the purpose of dealing with Pawfit user's Personal Information, information processing method, etc.;

2. Our control and organization structure changed greatly, such as the business adjustment, bankruptcy, merger and acquisition, etc.;

3. Our Pawfit user's Personal Information sharing, transfer or public disclosure main target change;

4. Our internal department charging the security, its contact information, and complaints channels change;

5. Any Pawfit user information security impact assessment indicates that there is a high risk.

IX. How to contact us

If you have any questions or concerns about this Policy and/or data processing of Pawfit, you may contact us by emailing to support@latsen.com or writing to the following address:

Pawfit Team, Latsen Technology LTD., Unit 19A, The Matchworks, Speke Road, Liverpool, L19 2RF, United Kingdom

Generally, we will reply to you upon the receipt of your query as soon as possible but not exceeding thirty (30) calendar day.