LEEWOO SOLUTION AMERICA, CORP. — California Privacy Policy

LEEWOO SOLUTION AMERICA, CORP. ("Company," "we," "us," or "our") is a systems integrator specializing in security systems, structured cabling, and audio/visual (A/V) systems, as well as other low-voltage systems for buildings and factories.

This Privacy Policy describes how the Company collects, uses, and discloses personal information in connection with our website.

Notice regarding CCPA applicability. The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, "CCPA," Cal. Civ. Code § 1798.100 et seq.), applies only to businesses that (1) have annual gross revenue exceeding a statutory threshold (inflation-adjusted to $26,625,000 for 2026), (2) annually buy, sell, or share the personal information of 100,000 or more California consumers or households, or (3) derive 50% or more of annual revenue from selling or sharing personal information. The Company does not currently meet any of these three thresholds and therefore does not believe it is a "covered business" under the CCPA. Nonetheless, as a matter of company policy and regardless of any legal obligation to do so, we have chosen to structure this Privacy Policy around the CCPA's disclosure framework and to voluntarily honor the rights described below. References in this document to "rights" and "response timelines" reflect voluntary commitments by the Company, not obligations imposed by statute.
CCPA-covered business No (voluntary compliance) Direct collection None Automatic collection Identifiers & internet activity via cookies (Google Analytics) Sold or shared No Retention Per Google's data retention policy
1

Categories of Personal Information We Collect

CCPA (Cal. Civ. Code § 1798.140(v)(1)) defines 11 statutory categories of personal information. The table below discloses, for each category, whether we collect it through our website in the preceding 12 months.

CategoryCollected
A. Identifiers (e.g., IP address, cookie/device identifiers)Yes
B. Categories under Cal. Civ. Code § 1798.80(e) (e.g., name, SSN, financial account)No
C. Protected classification characteristics (e.g., race, gender, age)No
D. Commercial information (e.g., purchase history)No
E. Biometric informationNo
F. Internet or other electronic network activity (e.g., browsing behavior, pages viewed)Yes
G. Geolocation dataNo
H. Audio, electronic, visual, thermal, olfactory, or similar informationNo
I. Professional or employment-related informationNo
J. Non-public education information (FERPA)No
K. Inferences drawn from any of the aboveNo

Sensitive personal information: We do not collect sensitive personal information (as defined by CPRA, Cal. Civ. Code § 1798.140(ae)) through our website — this includes government identifiers, financial account credentials, precise geolocation, racial or ethnic origin, religious beliefs, union membership, contents of private communications, genetic or biometric data processed for identification, health information, sexual orientation, and neural data.

2

Sources of Personal Information

We do not collect personal information directly from you (for example, through a contact form or account registration). The categories identified in Section 1 above are collected automatically from your browser via cookies when you visit our website.

3

Business Purposes for Collection and Use

  • Analyzing website traffic and visitor behavior to understand how our website is used
  • Auditing and improving the content, structure, and performance of our website

We do not use the information described above for any purpose incompatible with these stated purposes, and we do not use it to make automated decisions producing legal or similarly significant effects concerning you.

4

Retention Period

We do not separately store the information collected through Google Analytics. This information resides on servers operated by Google LLC and is retained according to Google's own data retention criteria, as described at https://policies.google.com/privacy.

5

Categories of Third Parties We Disclose Information To

We disclose the following category of personal information to the following category of third party, solely as our analytics service provider:

Category of personal information disclosedCategory of recipientPurpose
Identifiers; internet activity informationAnalytics service provider (Google LLC)Website analytics
6

We Do Not Sell or Share Personal Information

In the preceding 12 months, we have not sold or "shared" (as that term is defined under CCPA for cross-context behavioral advertising) any personal information, and we have no present plans to do so. We have not enabled Google Signals or any Google Analytics advertising features on our website.

As noted in Section 6, because we do not sell or share personal information, the right to opt-out described in Section 7 below has no practical occasion to be exercised — we nonetheless describe it here for reference, consistent with the voluntary CCPA-aligned framework described at the top of this page.

7

Privacy Rights We Voluntarily Extend to California Residents

As explained above, the Company does not believe it is a "covered business" under the CCPA. Nonetheless, we voluntarily extend the following rights to California residents, modeled on the corresponding CCPA provisions:

  • Right to Know (modeled on Cal. Civ. Code § 1798.110) — the specific pieces and categories of personal information we have collected about you, the sources, the purpose of collection, and the categories of third parties with whom it is disclosed.
  • Right to Delete (modeled on § 1798.105) — request deletion of personal information we have collected from you.
  • Right to Correct (modeled on § 1798.106) — request correction of inaccurate personal information.
  • Right to Opt-Out of Sale/Sharing (modeled on § 1798.120) — as noted in Section 6, this does not currently apply as we do not sell or share personal information.
  • Right to Limit Use of Sensitive Personal Information (modeled on § 1798.121) — not currently applicable, as we do not collect sensitive personal information.
  • Right to Non-Discrimination (modeled on § 1798.125) — we will not deny you goods or services, charge different prices, or provide a different level or quality of goods or services because you exercised any of the above rights.
8

How to Exercise These Rights

Submission method. Because our business operates exclusively online and does not have a direct relationship with consumers from whom we collect personal information, we designate a single method for submitting requests, to keep the process simple: the email address listed in Section 13 below.

Verification. To protect your information, we will take reasonable steps to verify your identity before fulfilling a request under Section 7. We may ask you for additional information solely for this verification purpose. You may also designate an authorized agent to submit a request on your behalf, subject to our ability to verify the agent's authority to act on your behalf.

Response timeline (voluntary target). We aim to confirm receipt of your request within 10 business days and to provide a substantive response within 45 calendar days of receipt, free of charge. If needed, this period may be extended once by an additional 45 days (90 days total), and we will notify you of any such extension within the initial 45-day period. (This timeline mirrors the timeline the CCPA imposes on covered businesses; we adopt it voluntarily as a service goal, not as a statutory obligation.)

9

Security Measures

Consistent with Cal. Civ. Code § 1798.100(e), we implement reasonable security procedures and practices appropriate to the nature of the limited information we collect, including:

  • Administrative safeguards: internal policies and minimizing personnel with access
  • Technical safeguards: access control for website administrator accounts, antivirus software installation and regular updates
  • Physical safeguards: access control over materials and media related to website operations
10

Cookies and Google Analytics

We use Google Analytics, a web analytics service provided by Google LLC, to understand how visitors use our website. Google Analytics uses cookies — small text files placed on your device — to collect standard internet log information and visitor behavior information.

Third-party (Google) data collection. We have installed Google Analytics on our website, through which Google collects information such as access information and service usage records. We do not provide Google with information that directly identifies you (such as your name or email address).

How to opt out. You may refuse the use of cookies through your browser's settings, or by installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout. Disabling cookies may affect certain features of our website.

Do Not Track signals. Our website does not currently respond to "Do Not Track" browser signals.

11

Children's Privacy

Our website is not directed to consumers under the age of 16, and consistent with the opt-in consent standard set out in Cal. Civ. Code § 1798.120(c)-(d), we do not knowingly collect or sell personal information of consumers under 16 without such consent.

12

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will post the updated policy on this page with a revised notice date.

- Notice date: September 10, 2026
- Effective date: September 10, 2026

13

Contact Us / Privacy Inquiries

If you have any questions about this Privacy Policy, or wish to exercise your California privacy rights, please contact us using the information below.

Note: as described in Section 8, our website currently operates exclusively online with no direct consumer relationship, so email is our designated CCPA request method. If our business practices change (e.g., we begin selling products directly to consumers or creating accounts), we will add the additional request methods CCPA requires at that time.

LEEWOO SOLUTION AMERICA, CORP. · California Privacy Policy