PICK User Privacy Policy

Effective Date: April 1, 2025

Little Grass Co. Limited ("we", "our", or "us") is committed to protecting the privacy and personal data of all users of the PICK platform ("you", "your", or "user"). This Privacy Policy ("Policy") describes how we collect, use, disclose, and protect your personal information in compliance with applicable data protection laws and regulations, including the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and, where applicable, the California Consumer Privacy Act (CCPA) and other relevant privacy laws in the United States.

Please read this Policy carefully. By using or accessing the PICK platform, you acknowledge that you have read, understood, and agreed to the practices described in this Policy.

Collection and Use of Personal Data

We collect personal data that is necessary for providing and improving our services, enhancing user experience, ensuring security, and meeting our legal obligations. This includes but is not limited to:

• Identification information (e.g., name, email address)
• Device information (e.g., IP address, browser type, device model)
• Usage data (e.g., features accessed, time spent on the app)

We only collect personal data lawfully, fairly, and for specific purposes. We will not use your personal information for any new purpose without your prior consent unless required by law.

Disclosure and Transfer of Personal Data

We do not sell your personal information. We may share your personal data in the following circumstances:

• With your explicit consent
• With service providers or partners who assist in providing services (under strict confidentiality obligations)
• Where required to comply with applicable laws, legal obligations, or law enforcement requests
• In the event of a merger, acquisition, or sale of assets, where your data may be transferred as part of that transaction

All data transfers, including international transfers (if any), will be carried out in accordance with legal safeguards to ensure adequate protection of your personal data.

Use of Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Recognize returning users
• Analyze traffic and usage patterns
• Deliver customized content and services

You can manage or disable cookies via your browser settings. Please note that disabling cookies may affect the functionality of our platform.

Data Retention and Security

We retain your personal information only for as long as is necessary to fulfill the purposes outlined in this Policy or as required by law.

We implement appropriate technical and organizational measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction, including:

• Encryption of data in transit and at rest
• Access controls and authentication mechanisms
• Regular security assessments and audits

Your Rights

You have the right to:

• Access your personal data
• Request correction of inaccurate or incomplete data
• Request deletion of your data under certain conditions
• Withdraw consent for processing where applicable
• Opt out of direct marketing communications

To exercise these rights, please contact us using the details provided in the "Contact Us" section below. We will respond within the timeframes required by law.

Children's Privacy

Our platform is not intended for use by minors under the age of 18 without parental or guardian consent. We do not knowingly collect personal information from children without proper consent. If we become aware that we have collected personal data from a minor without verification of parental consent, we will delete that data promptly.

Policy Updates

We may revise this Policy from time to time to reflect changes in our practices, services, or applicable laws. We will notify you of any material changes by posting the updated Policy on our platform and updating the "Effective Date" above.

By continuing to use our services, you agree to the terms of this Privacy Policy. We are committed to protecting your privacy and welcome your feedback and inquiries.