PRIVACY POLICY

Effective Date: 10 September 2026

This Privacy Policy explains what personal data is collected when you use the website located at leadpdfeditor.com (the “Website”), the online document productivity services, and features provided through it (collectively, the “Service”), as well as how such personal data is collected, stored, used, and shared.

By accessing or using the Service, you confirm that you have read, understood, and agreed to the practices described in this Privacy Policy. If you do not agree with these terms, you must discontinue your use of the Service immediately, close your account, and cancel any active trials or subscriptions.

TABLE OF CONTENTS

1. Personal Data Controller
2. Categories of Personal Data We Collect
3. Purposes and Legal Bases for Processing Personal Data
4. With Whom We Share Your Personal Data
5. Privacy Rights for EEA and UK Residents (GDPR)
6. International Data Transfers
7. U.S. States Privacy Notice
8. Consumer Health Data Privacy Notice
9. Data Retention
10. Age Limitation
11. Contact Us

1. PERSONAL DATA CONTROLLER

Earn Smart Corporation Limited, a company incorporated under the laws of Hong Kong, having its registered office at Unit S, 15/F., One Midtown, 11 Hoi Shing Road, Tsuen Wan, New Territories, Hong Kong, is the controller of your personal data.

For any inquiries, privacy concerns, or requests regarding your personal data, you can reach us at support@leadpdfeditor.com.

2. CATEGORIES OF PERSONAL DATA WE COLLECT

We collect personal data directly provided by you, as well as data generated automatically during your interaction with the Website.

2.1. Information Provided Directly by You

• Identifiers: Your name and email address provided during account registration, purchase checkout, or customer support inquiries.
• Account Credentials: Login email address, password, and unique user identifier.
• Purchase Data: Billing details submitted to complete paid transactions. Payment handling is performed directly by our payment processor, Oceanpayments. We do not store or collect full credit card numbers. We receive limited transaction details, such as the date, time, amount, payment method type, secure payment tokens, and partial card digits.
• Uploaded Content: Documents, files, images, forms, and electronic signatures uploaded or generated through the Service.
• Customer Support Communications: Correspondence sent to our support team via email or contact forms, including feedback, complaints, and ticket details.
• Customer Support Call Data: Information provided during telephone customer support calls, including recorded call audio and written transcripts where telephone calls are recorded or transcribed for verification and quality purposes.

2.2. Information Collected Automatically

• Referring URL: Information concerning the referring page or ad source that directed you to our Website.
• Device and Technical Data: Internet Protocol (IP) address, operating system version, browser type, device brand and model, language settings, time zone, Internet service provider, and mobile carrier.
• Usage Data: Interactions with the Website, including tools used (e.g., PDF editing, conversion, electronic signatures), pages visited, feature usage frequency, time spent on pages, and transaction actions.
• Advertising Identifiers and Tracking Technologies: Unique advertising identifiers (such as IDFA for iOS or AAID for Android) and data collected through cookies, tracking pixels, and web beacons.

3. PURPOSES AND LEGAL BASES FOR PROCESSING PERSONAL DATA

We process your personal data for specified operational, contractual, and marketing purposes. If you reside in the European Economic Area (EEA) or the United Kingdom (UK), our legal bases under the General Data Protection Regulation (GDPR) are outlined below:

3.1. To Provide and Deliver the Service

We use your identifiers, account credentials, and uploaded files to operate the Website, maintain your account, and perform requested document functions (such as editing, converting, merging, and signing PDFs).

• GDPR Legal Basis: Performance of a contract (Article 6(1)(b) GDPR).

3.2. To Process Payments and Billing

We process transaction records to enable subscriptions, fulfill purchases, and verify payment completion via Oceanpayments.

• GDPR Legal Basis: Performance of a contract (Article 6(1)(b) GDPR) and legal obligations (Article 6(1)(c) GDPR).

3.3. To Provide Customer Support

We process your contact details, support communications, and call data to answer technical inquiries, resolve billing issues, document requests, and address complaints.

• GDPR Legal Basis: Performance of a contract (Article 6(1)(b) GDPR) and legitimate interests in maintaining customer satisfaction and service quality (Article 6(1)(f) GDPR).

3.4. To Analyze and Improve the Service

We use web analytics tools—specifically Google Analytics and Hotjar—to evaluate user navigation, identify technical errors, assess feature adoption, and optimize Website layout and functionality. Hotjar provides behavioral insights through aggregated session recordings, surveys, and heatmaps. Google Analytics processes device identifiers and interaction data.

• GDPR Legal Basis: Legitimate interests in improving and optimizing our online platform (Article 6(1)(f) GDPR) or consent where required by applicable local law (Article 6(1)(a) GDPR).

3.5. To Serve and Personalize Advertisements

We utilize Google Ads to deliver, tailor, and measure online advertising campaigns. Google Ads uses cookies and device identifiers to show relevant advertisements to prospective and returning users based on their interactions with our Website.

• GDPR Legal Basis: Consent (Article 6(1)(a) GDPR). You may withdraw consent or opt out of personalized ads at any time through your device settings or via Google Ad Settings.

3.6. To Enforce Terms, Prevent Fraud, and Comply with Legal Duties

We process personal data to protect against unauthorized access, investigate fraudulent transactions, resolve chargeback disputes, enforce our Terms and Conditions, and fulfill statutory tax or reporting requirements.

• GDPR Legal Basis: Compliance with legal obligations (Article 6(1)(c) GDPR) and legitimate interests in safeguarding legal rights and protecting against fraud (Article 6(1)(f) GDPR).

4. WITH WHOM WE SHARE YOUR PERSONAL DATA

We do not sell your personal data for monetary payment. We share personal data with selected service providers and third parties under strict processing obligations:

• Payment Processors: Oceanpayments, to process billing transactions, maintain payment records, and prevent payment fraud.
• Analytics Providers: Google Analytics and Hotjar, to analyze traffic patterns and user behavior.
• Marketing and Advertising Partners: Google Ads, to execute targeted advertising campaigns and measure conversion performance.
• Cloud Storage and Infrastructure Services: Hosting and data storage providers that maintain secure server infrastructure for operating the Website.
• Corporate Group and Affiliates: Companies within our corporate group that adhere to data protection standards aligned with this Privacy Policy.
• Law Enforcement and Public Authorities: Courts, regulatory authorities, or law enforcement bodies when legally required to comply with binding legal orders, court summonses, or statutory obligations.
• Corporate Transactions: Prospective buyers, legal advisors, and financial auditing teams in connection with a corporate reorganization, merger, asset acquisition, or business transfer.

5. PRIVACY RIGHTS FOR EEA AND UK RESIDENTS (GDPR)

If you reside in the EEA or the United Kingdom, you hold specific statutory privacy rights under the GDPR and UK GDPR:

• Right of Access: You have the right to request a copy of the personal data we hold about you.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data.
• Right to Erasure (Right to be Forgotten): You may request the deletion of your personal data, subject to statutory record-retention requirements.
• Right to Restrict Processing: You may request that we temporarily or permanently restrict the processing of your personal data under certain conditions.
• Right to Data Portability: You may request your personal data in a structured, commonly used, and machine-readable format for transfer to another controller.
• Right to Object: You have the right to object to processing based on legitimate interests or direct marketing.
• Right to Withdraw Consent: Where processing relies on consent, you may withdraw your consent at any time without affecting the lawfulness of prior processing.
• Right to Lodge a Complaint: You have the right to submit a complaint to the competent Data Protection Authority in your jurisdiction.

To exercise any of these rights, please contact our privacy representative at support@leadpdfeditor.com.

6. INTERNATIONAL DATA TRANSFERS

Personal data collected by Earn Smart Corporation Limited may be stored or processed outside your home jurisdiction. When transferring personal data from the EEA or UK to countries that have not received an adequacy decision by the European Commission, we rely on standard data protection clauses approved by the European Commission (Standard Contractual Clauses) to ensure an adequate level of data protection.

7. U.S. STATES PRIVACY NOTICE

This section applies solely to residents of U.S. states that have enacted comprehensive consumer privacy statutes, including California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia.

7.1. Summary of Personal Information Collected and Disclosed

7.2. Your Privacy Rights Under U.S. State Laws

Eligible U.S. residents possess the following rights regarding their personal information:

• Right to Know and Access: The right to request information regarding the categories and specific pieces of personal information collected, sources, purposes, and third parties receiving the data.
• Right to Deletion: The right to request deletion of personal information, subject to statutory exemptions.
• Right to Correction: The right to request correction of inaccurate personal information.
• Right to Opt-Out of Targeted Advertising & Sharing: The right to direct us not to share or process your personal information for cross-context behavioral advertising.
• Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising statutory privacy rights.

To exercise your U.S. state privacy rights, please submit a written request to support@leadpdfeditor.com. We will verify your identity by matching data points provided in your request against information in our account systems. Authorized agents submitting requests on behalf of a consumer must provide proof of written authorization.

8. CONSUMER HEALTH DATA PRIVACY NOTICE

This Consumer Health Data Privacy Notice applies to personal information considered “consumer health data” under applicable U.S. state laws, such as Washington’s My Health My Data Act and similar state statutes.

8.1. Nature of Processing

Lead PDF Editor is a general-purpose online document editor and productivity platform. We are not a healthcare provider, medical facility, or health platform. We do not request, require, or intentionally seek to create health profiles or gather consumer health data from users.

8.2. User-Submitted Health Data

Users independently select files, PDFs, images, and text to upload to the Website. If an uploaded document or a communication sent to customer support contains health-related details, we process that data solely to execute the document editing, conversion, storage, or customer support function requested by the user.

8.3. No Secondary Use or Sale

We do not isolate, profile, sell, or disclose user-submitted health data for marketing, profiling, advertising, or secondary commercial purposes. Such data is processed strictly in accordance with user instructions and system functionality. You may exercise health data deletion or access rights by contacting support@leadpdfeditor.com.

9. DATA RETENTION

We retain personal data only for as long as necessary to fulfill the operational, legal, and contractual purposes set forth in this Privacy Policy:

• Guest Document Uploads: Files uploaded by users who do not hold or log into an active account are automatically and permanently deleted from our primary servers within 3 to 7 days of upload.
• Registered Account Content: Documents saved in registered user accounts are retained for the duration of active account status or until deleted by the user. Upon account closure or termination, files may be permanently removed.
• Customer Support Call Audio Recordings: Recorded telephone support call audio is retained for up to 3 months from the date of the call.
• Customer Support Call Transcripts: Written transcripts of telephone support calls are retained for up to 6 months from the date of the call. Where a transcript or recording is relevant to an ongoing legal dispute, fraud investigation, or formal complaint, it may be retained longer as necessary to resolve the matter.
• Account and Transaction Records: Financial records, invoice histories, and account activity logs are retained following account closure as required by statutory accounting, tax, anti-fraud, and legal limitation periods.

10. AGE LIMITATION

The Service is intended solely for adult users. We do not knowingly solicit, collect, or process personal data from individuals under 18 years of age. If you believe a minor under 18 has submitted personal data to us, please contact us immediately at support@leadpdfeditor.com, and we will take prompt steps to remove such records.

11. CONTACT US

If you have questions, feedback, or privacy rights requests regarding this Privacy Policy or our data handling practices, please contact us:

Earn Smart Corporation Limited
Unit S, 15/F., One Midtown
11 Hoi Shing Road, Tsuen Wan
New Territories, Hong Kong

Customer Support & Privacy Contact: support@leadpdfeditor.com