Privacy Policy

Last Updated: May 14, 2026

This Privacy Policy explains how PAPER TRACKER TECHNOLOGY LIMITED, operating under the PaperTracker brand ("PaperTracker", "we", "our", or "us"), collects, uses, discloses, stores, and otherwise processes personal information in connection with our websites, online store, products, software, support services, and related services (collectively, the "Services").

This Privacy Policy is provided in English and Chinese for convenience. To the maximum extent permitted by applicable law, the English version prevails in the event of any inconsistency.

1. Scope

This Privacy Policy applies to personal information we collect from or about you in connection with the Services, including when you browse our website, place an order, use our software, contact support, participate in promotions, submit warranty requests, or choose to join an optional Data Contribution Program.

2. Information We Collect

2.1 Information you provide directly

We may collect information you provide directly to us, including:

• name, email address, phone number, shipping address, billing address, and order details;
• account credentials and profile information if you create an account;
• customer-support communications, warranty claims, survey responses, contest entries, and other messages you send us;
• prescription or fitting information you submit for Custom Products such as custom lenses;
• logs, screenshots, videos, recordings, diagnostic packages, or other materials you choose to send to us; and
• information you submit when you join an optional Data Contribution Program.

2.2 Information collected automatically

We may collect certain technical and usage information automatically when you use the Services, such as:

• device type, operating system, browser type, app version, firmware version, language settings, and general diagnostic information;
• IP address, approximate region derived from IP, timestamps, crash data, error reports, and security logs;
• website usage information collected through cookies, pixels, local storage, or similar technologies; and
• checkout, cart, fraud-prevention, and store-security related events.

2.3 Payments

Payments are usually processed by third-party payment providers. We do not intentionally store full payment-card numbers unless strictly necessary and lawfully permitted. Payment processors handle payment data under their own terms and privacy policies.

2.4 Face and Eye Data: default local processing

In the ordinary default use of Paper_Tracker products and software, face-tracking data, eye-tracking data, gaze outputs, expression outputs, calibration data, and related inputs and outputs ("Face and Eye Data") are processed locally on your device for core product functionality. In default mode, we do not upload Face and Eye Data to our servers, we do not store Face and Eye Data on our servers, and we do not perform server-side analysis of Face and Eye Data.

2.5 Optional Data Contribution Program

We may offer an optional Data Contribution Program for dataset construction, model training, evaluation, debugging, robustness analysis, fairness analysis, product improvement, and related research and development. Participation is entirely voluntary and requires a separate, explicit consent flow. If you join, we may collect and process the Face and Eye Data and related metadata that you choose to contribute, as described in the separate consent notice.

2.6 Support submissions containing Face and Eye Data

If you voluntarily send us logs, screenshots, recordings, or other support materials that include Face and Eye Data, we may process those materials for troubleshooting, support, security, abuse prevention, warranty evaluation, and product-quality purposes.

3. How We Use Personal Information

We may use personal information for the following purposes:

1. to process and fulfill orders, handle shipping, customs-support communications, payments, returns, refunds, warranty requests, and customer service;
2. to provide, operate, maintain, authenticate, secure, debug, and improve the Services;
3. to install or deliver software, firmware, updates, patches, and device-related functionality;
4. to detect, investigate, prevent, and respond to fraud, abuse, security incidents, unauthorized access, and legal claims;
5. to communicate with you about your orders, support requests, software changes, security notices, and operational updates;
6. to send marketing communications where permitted by law and subject to your choices;
7. to conduct internal analytics, quality control, research, testing, and service planning;
8. where you separately consent, to collect and use contributed Face and Eye Data for the Optional Data Contribution Program; and
9. to comply with legal obligations and enforce our agreements, policies, and rights.

4. Legal Bases

Where required by applicable law, we process personal information on one or more of the following legal bases:

• performance of a contract with you;
• compliance with a legal obligation;
• our legitimate interests, such as operating and securing our business, improving our Services, preventing fraud, and supporting users;
• your consent, including explicit consent where required for certain categories of data or certain uses; and
• other lawful bases available under applicable law.

5. How We Share Personal Information

We may disclose personal information to:

1. payment processors, e-commerce platform providers, fraud-prevention providers, cloud-hosting providers, analytics providers, communication providers, and other service providers acting on our behalf;
2. logistics carriers, warehouse providers, customs brokers, insurers, and after-sales or repair partners involved in fulfilling or supporting your order;
3. professional advisers, auditors, insurers, banks, and corporate affiliates, where reasonably necessary;
4. authorities, regulators, courts, or law-enforcement bodies where required by law, subpoena, court order, or to protect rights, safety, and security; and
5. a buyer, investor, merger partner, or other successor in connection with a corporate transaction, subject to appropriate safeguards.

We may also share information with third parties when you ask us to do so, direct us to do so, or expressly consent.

We do not sell, lease, or trade Face and Eye Data as identifiable biometric information. We do not use Face and Eye Data contributed under the Optional Data Contribution Program for advertising profiling.

6. Cookies and Similar Technologies

We and our service providers may use cookies, local storage, pixels, and similar technologies for shopping-cart functionality, login sessions, fraud prevention, analytics, user preferences, site performance, and operational security. Depending on your location, you may be presented with cookie choices or controls where required by law.

7. International Data Transfers

We are a Hong Kong company, and your personal information may be processed in Hong Kong and in other countries or regions where we or our service providers operate. Those locations may have data-protection laws that differ from the laws of your home country. Where required by applicable law, we will implement appropriate safeguards for cross-border transfers.

8. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, comply with legal obligations, resolve disputes, enforce agreements, and support security and business records.

For identifiable Face and Eye Data collected under the Optional Data Contribution Program, our default retention objective is to retain such data only until the original collection purpose has been satisfied or within three (3) years of the individual's last interaction with us, whichever occurs first, unless:

• a shorter period is required by law;
• the data is deleted or irreversibly de-identified sooner; or
• continued retention is strictly necessary for legal claims, audit, or security reasons to the extent permitted by law.

Withdrawal of consent stops new collection going forward but does not require us to reverse or unwind data that has already been irreversibly de-identified, aggregated, or incorporated into trained models, evaluation artifacts, or security records, to the extent permitted by law.

9. Data Security

We use reasonable technical, administrative, and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, or destruction. However, no internet transmission or storage system is completely secure, and we cannot guarantee absolute security.

10. Your Choices and Rights

Depending on your location and applicable law, you may have rights to:

• access, know, or receive a copy of certain personal information;
• correct inaccurate personal information;
• request deletion of personal information;
• object to or restrict certain processing;
• withdraw consent where processing is based on consent;
• request data portability; and
• lodge a complaint with an applicable supervisory or regulatory authority.

You may also opt out of marketing emails by using the unsubscribe link in the email or by contacting us. Operational, order-related, security, and warranty communications may still be sent even if you opt out of marketing communications.

If you joined the Optional Data Contribution Program, you may withdraw your consent at any time through available product settings or by contacting support@papertracker.top. Refusing or withdrawing consent for that optional program will not disable the core local tracking functionality of the product.

11. Children's Privacy

The Services are not directed to children below the age required to validly consent under applicable law. If you believe a child has provided us with personal information in violation of applicable law, please contact us so that we can take appropriate action.

12. Third-Party Services

Our Services may contain links to, or rely on, third-party services and platforms. Their privacy practices are governed by their own terms and privacy notices, not this Privacy Policy.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version becomes effective when posted, unless a later date is stated. If required by law, we will provide additional notice for material changes.

14. Contact Information

If you have questions, requests, or complaints about this Privacy Policy or our privacy practices, contact us at:

Paper_Tracker Legal Entity: PAPER TRACKER TECHNOLOGY LIMITED Company Registration Number: 80350152 Business Registration Number: 80350152-000-05-26-8 Email: support@papertracker.top

Registered Office / Business Address: RM502C, 5/F, HO KING COMM CTR, 2-16 FAYUEN ST, MONG KOK, HONG KONG

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