LIGHTMIND --PrivacyPolicy

Lightmind Privacy Policy V1.0

Lightmind Privacy Policy

Version: 1.0Effective Date: July 1, 2026Last Updated: July 1, 2026

Introduction

We designed Lightmind to put you in control of your skincare routine — and your privacy. This Privacy Policy explains what information the Lightmind app ("APP") collects, how it's used, and the choices you have.Lightmind is a companion control app for the LED Phototherapy Mask (Model: V2) ("Device"), a Class II medical device currently under FDA 510(k) review. The APP works only as a remote control for the Device. It does not diagnose, treat, or make medical decisions.By using Lightmind, you agree to the practices described in this Policy.

1. Information We Collect

We collect the minimum information needed to operate the APP and connect to the Device.Device Usage. When you use the Device through the APP, we record the treatment mode you select, the power level, the duration, and the date and time.Device Information. To identify your Device and deliver firmware updates, we collect the Device model, firmware version, and Bluetooth MAC address.Mobile Device Technical Information. To ensure compatibility and troubleshoot issues, we collect your operating system version, system language, time zone, screen resolution, screen density, and screen orientation. On iOS 17 and later, we may access device model identifiers such as "iPhone17,1" to verify compatibility — these are used only locally and are not transmitted.APP Operational Data. We collect the current APP version, package name, connection status, and battery level.Permissions We Request:

• Bluetooth. Required to scan for and connect to the Device.

• Location (Android 6.0+ only). Required by Android to enable Bluetooth scanning. We do not collect, store, or transmit location data.

What We Do NOT Collect

We explicitly do NOT collect:

• Your name, address, phone number, or email address

• Your precise or approximate geolocation

• Your photos or videos

• Your skin information, health data, or any biometric data

• Any personal data via device cameras, microphones, or sensors

• Contacts, calendar, or any other device sensor data

• Account credentials (the APP does not require account registration)

• Advertising identifiers — Apple's Identifier for Advertisers (IDFA), Google's Advertising ID (GAID/AAID)

• Persistent device tracking identifiers — we do not use Apple's Identifier for Vendor (IDFV) or any similar persistent identifier for cross-app tracking

• Purchase history, financial information, or any payment data

• Browsing history, search history, or any user activity outside the APP

 

2. How We Use Your Information

We use the collected information solely for:

• Providing core APP functionality (Device control, treatment history, firmware updates)

• Displaying Device status, battery level, and connection state

• Recording treatment history for your personal reference (locally on your device)

• Troubleshooting and improving APP performanceWe do NOT use your information for:

• Marketing, advertising, or any commercial promotion

• User profiling, behavioral analysis, or AI training

• Sale, lease, or transfer to any third party

• Any purpose unrelated to the Device and APP functionality

 

3. Data Storage and Security

Local Storage Only

All your data is stored locally on your personal mobile device:

• iOS: Core Data

• Android: SQLiteNo data is uploaded to any cloud server, remote database, or any third-party system by the Company.

Data Retention

• Treatment records: retained for the most recent 30 days; older records are automatically deleted.

• Firmware update records: retained until the APP is uninstalled.

• All local data is permanently deleted when the APP is uninstalled.

Security Measures

• All Bluetooth communication is encrypted with AES-128 to prevent eavesdropping.

• Firmware upgrade packages are protected by digital signature verification to prevent malicious firmware injection.

• The APP follows industry-standard security practices to protect on-device data.

 

4. Third-Party Services

Lightmind does not include any third-party SDKs. We don't use analytics, advertising, social sharing, push notifications, or payment services. Nothing in Lightmind sends your data to a third party.The APP does not integrate any third-party SDKs, including but not limited to:

• Analytics: Google Analytics, Firebase Analytics, Umeng, TalkingData

• Crash monitoring: Firebase Crashlytics, Bugly, Sentry

• Advertising: any ad SDK

• Social sharing: Facebook SDK, WeChat SDK, Twitter SDK

• Payment: any payment SDK

• Push notifications: any push SDK

 

5. Your Rights

You can exercise these rights at any time:

• Access. Request a copy of the personal information we hold about you.

• Correct. Ask us to correct information that is wrong.

• Delete. Ask us to delete your information.

• Restrict. Ask us to limit how we use your information.

• Portability. Receive your information in a machine-readable format.

• Withdraw consent. Stop us from processing your information by uninstalling the APP or disabling permissions.To exercise these rights, contact us at lightmindmask@guangsiwei.com. We'll respond within 30 days for GDPR requests, or 45 days for CCPA requests.You also have the right to lodge a complaint with your local data protection authority.

 

6. Children's Privacy

The Lightmind APP is intended exclusively for adult users (18 years of age or older) and is not directed at children under the age of 16. We do not knowingly collect, use, or disclose personal information from children under 16.Age Thresholds by Jurisdiction:

• United States: COPPA applies to children under 13

• European Economic Area / United Kingdom: GDPR sets the digital consent age at 16 (Member States may lower to 13)

• China: PIPL sets the personal information consent age at 14

• Other jurisdictions: applicable local lawParental Notice: If you are a parent or legal guardian and believe your child under the applicable age threshold has used the APP or provided us with personal information, please contact us immediately at lightmindmask@guangsiwei.com. Upon verification, we will:(a) Investigate the matter within 7 business days;(b) Delete all personal information collected from the child;(c) Confirm the deletion in writing to the parent or guardian; and(d) Implement measures to prevent recurrence.No Verifiable Parental Consent: If we become aware that we have collected personal information from a child under the applicable age threshold without verifiable parental consent (as required by COPPA), we will delete such information as soon as possible.Verifiable Parental Consent Methods (COPPA): For users in the United States, verifiable parental consent may be obtained through:

• A signed consent form returned via mail or fax

• A credit card, debit card, or other online payment method

• A toll-free telephone call with trained personnel

• A video conference

• Government-issued ID checked against databasesNo Marketing to Children: The APP contains no content directed at minors. We do not use any information collected through the APP for marketing or behavioral targeting of minors.Contact: For any questions regarding children's privacy, contact us at lightmindmask@guangsiwei.com.

 

7. International Data Transfers

The APP does NOT transfer any data outside of your personal mobile device to servers controlled by the Company or any third party. As such, there are no international data transfers from Company servers (we operate no servers that receive your data).The Company is headquartered in Shenzhen, China. By using the APP, you acknowledge that any privacy inquiries or disputes will be handled in accordance with the contact information provided in this Policy.

8. FDA Regulatory Notice

The Lightmind APP is a companion control tool for the LED Phototherapy Mask (Model: V2) ("Device"), a Class II medical device. The Device is currently under review by the **U.S. Food and Drug Administration (FDA) through the 510(k) premarket notification process and has not yet received FDA 510(k) clearance.**Important Notice:

• The Device is not currently available for sale, distribution, or use within the United States; such availability will occur only after the Device receives all required FDA clearances and the APP is updated accordingly.

• The APP itself is software and may be made available in app stores in regions where appropriate. However, the APP does not promote, advertise, or facilitate the sale of the Device in any region where such sale is not yet legally permitted.

• The Device is currently available in the People's Republic of China and the European Union (subject to applicable local regulations).

• The APP has not been evaluated by the FDA.

• The APP does not contain any medical claims, nor does it claim any therapeutic, diagnostic, or improvement effects.

• The APP is not intended to diagnose, treat, cure, or prevent any disease or medical condition.

• The APP functions solely as a hardware remote control for the Device.

• Data collected by the APP does NOT constitute Protected Health Information (PHI) as defined under the Health Insurance Portability and Accountability Act (HIPAA).

 

9. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).Sale and Sharing of Personal Information:

• We do not sell your personal information.

• We do not share your personal information for cross-context behavioral advertising.

• We have not sold or shared personal information in the preceding 12 months, and we have no actual knowledge of selling or sharing personal information of users under 16 years of age.Your Rights:

• Right to Know — what categories of personal information we collect, the sources, and the business purposes

• Right to Delete — personal information we have collected from you

• Right to Correct — inaccurate personal information

• Right to Opt-Out of Sale or Sharing — (not applicable, as we do not sell or share)

• Right to Limit Use of Sensitive Personal Information — (not applicable, as we do not collect sensitive personal information)

• Right to Non-Discrimination — for exercising your CCPA/CPRA rights

• Right to Data Portability****Categories of Personal Information Collected (CCPA):

• Identifiers: device model identifier (e.g., iPhone17,1), Bluetooth MAC address

• Commercial information: treatment mode, power level, duration

• Internet or other electronic network activity information: APP version, connection status

• Inferences: noneCategories of Sensitive Personal Information Collected: None.Retention period: 30 days for treatment records; until APP uninstallation for firmware update records and device information.Response Time: We will respond to verifiable consumer requests within 45 days as required by CCPA. If we need additional time, we will notify you of the extension (up to a maximum of 90 days total).Authorized Agent: You may designate an authorized agent to submit a request on your behalf. We will require proof of authorization.Shine the Light Law (California Civil Code §1798.83): We do not disclose personal information to third parties for their direct marketing purposes.To exercise these rights, contact us at lightmindmask@guangsiwei.com.

 

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you via an in-APP notice before the changes take effect.The "Effective Date" and "Version" at the top of this Policy indicate when it was last updated. Your continued use of the APP after the effective date of any changes constitutes your acceptance of the updated Policy.

11. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:Data Controller: Shenzhen Lightmind Intelligent Electric Co., Ltd.Address: Room 101, Building 2, No. 59 Paotai Road, Lisongmeng Community, Gongming Street, Guangming District, Shenzhen, Guangdong 518106, ChinaEmail: lightmindmask@guangsiwei.comResponse Time: Within 30 days (GDPR) or 45 days (CCPA)

End of Privacy PolicyVersion 1.0 | Effective Date: July 1, 2026