Privacy Policy

Effective Date: October 10, 2025

To better protect your privacy and security, we have formulated this Privacy Policy (hereinafter referred to as "this Policy") to inform you about how we collect, use, disclose, protect, store, and transfer your personal data.

1.Scope of Application

This Policy applies to personal data processing activities involved when you use MakeRoad (domain name: makeroad.com, operating entity: "MAKEROAD HONG KONG HOLDINGS LIMITED"), associated mobile applications, mini-programs, offline events, and customer services.

2.Types of Information We Collect

We collect both personal and non-personal information from users, such as anonymous information. "Personal Information" refers to information that can be used to contact or identify you, such as your full name, email address, phone number, payment methods, and profile picture, as well as information associated with this Personal Information. "Anonymous Information" refers to information that is not associated with your Personal Information, cannot be used to contact or identify you, and is not associated with information that could be used to contact or identify you (like Personal Information). Anonymous Information includes passively collected information about your activities on the website or service or your use of our software, such as usage data, provided this information is not associated with your Personal Information.

Information You Actively Provide to Us

(1)Account Information: When registering an account, you need to provide personal information, including your email address or mobile phone number, verification code, and password. You may also provide us with other information, such as gender, date of birth, country, language, and other details. When you register/log in using a third-party account (e.g., Google, Apple, Facebook), we will obtain publicly available information related to you, such as your avatar and nickname, as well as other information you authorize from these third parties.

(2)Contact/Feedback: If you purchase goods or seek other services on the platform, you may provide us with contact information, including your name, nickname, email address, shipping address, contact number, or online form information. When providing logistics and delivery services, we will share your contact information with third-party logistics organizations to complete the delivery service.

(3)Content Data: When you upload your 3D model files, images, videos, or other files on MakeRoad, or post text or image information in models or the community, we may store this content data. If such content includes third-party information, you should obtain permission from the third party and inform them of this Privacy Policy before uploading. Without your consent or authorization, we will not automatically collect such files from you.

(4)Purchase and Payment: If you purchase goods or services on MakeRoad, we need to share your order number and amount information with payment institutions to complete payment confirmation.

(5)Transaction Information: When you purchase goods or services from Makeroad, we may also need to collect your transaction records, including but not limited to details of your purchase history.

Information Collected Automatically

(1)Device and Network Information: When you visit our website or mobile application, you may provide us with information related to the operation of your browser or application, such as IP address, browser or device serial number, operating system, etc.

(2)Behavioral Information: We may use automatic data collection technologies to record certain information about your IP address, access device, browser type, browsing behavior, and patterns. This data is used only for website operation analysis and statistics and does not include personal information.

(3)Diagnostic Information: We collect information during the operation of our services, including functionality, performance, logs, error reports, or memory state during application crashes.

(4)Log Data: Includes, but is not limited to, timestamps, user behavior content, IP address, etc.

We base this type of data processing on legitimate interests pursuant to Article 6(1)(f) GDPR. You have the right to withdraw your consent to data collection at any time via Cookie settings or personal settings in the User Center. Upon withdrawal, we will stop the relevant data collection activities, but this may affect the use of some features.

3.How We Use Your Personal Information

• We process your personal data in accordance with this Privacy Policy and your choice settings when providing user account management, content, and services.

• We understand and analyze user trends, preferences, and usage feedback to improve the products and services offered by the platform.

• We may contact you for management and service purposes, send you corresponding content information based on your preference settings, and may also send marketing information related to products or services offered by our cooperative third parties. You can modify your subscription preferences at any time.

• We will not share, transfer, or publicly disclose your personal information to any third party without your consent, unless otherwise provided by laws and regulations, or involving national security, national defense, public interest, other criminal acts, etc.

4.How We Use Cookies

To make our website more attractive, we use Cookies on various pages of the website. These are small text files stored on your computer or mobile device by a web server. Most Cookies are deleted from your hard drive immediately after your browser session ends (so-called session cookies). Other Cookies remain on your computer's hard drive, allowing us to recognize your computer during subsequent visits to our website (so-called persistent cookies). These files make our website more user-friendly, efficient, and secure. For example, these files allow you to navigate from one page of the website to another without having to log in again; we can also display information or advertisements on specific web pages that are particularly tailored to your personal preferences or interests. Once the retention period expires, these Cookies are automatically deleted.

You can manage or delete Cookies based on your preferences. Please note that some of our services may require the use of Cookies, and disabling them may affect your use of these features or services.

5.How We Share Your Personal Information with Third Parties

We highly value protecting the scope of use of your personal information and will only share your personal information with companies and organizations outside of Makeroad under the following circumstances:

• Direct Authorized Sharing: After obtaining your explicit consent, we will share your personal information with relevant third parties within the scope of your consent. The specific third parties involved will be listed and updated in real-time in the Cookie settings, which you can view and modify at any time through the "Cookie Settings" function.

• Sharing as Required by Law: According to the provisions of laws and regulations, if required by legal procedures, or upon request by state law enforcement agencies and relevant departments in accordance with the law, we may disclose necessary personal information.

• Sharing with Authorized Partners: We will share necessary personal information with affiliated partner companies, including your order information, account information, device information, and location information, to ensure the successful completion of the services provided by the platform. Partner companies will be bound by this Privacy Policy. If sharing exceeds this scope, we will seek your authorization again.

6.Your Legal Rights

Your Rights (Articles 12–23 GDPR, CCPA §1798.100–105)

• Right of Access: Obtain a copy of the personal data we hold about you.

• Right to Rectification: Correct inaccurate or incomplete data.

• Right to Erasure / Right to Be Forgotten: Delete data, subject to statutory exceptions.

• Right to Restriction of Processing: Suspend processing during a dispute.

• Right to Data Portability: Receive your data in a structured, commonly used, and machine-readable format and transmit it to a third party.

• Right to Object: Object at any time to processing based on legitimate interests or for direct marketing purposes.

• Automated Decision-Making: We currently do not use automated decision-making that produces legal effects concerning you or similarly significantly affects you.

To exercise your rights, please email official@makeroad.com. We will respond within 30 days. If you are located in the EU and are dissatisfied with our response, you have the right to lodge a complaint with your local data protection authority.

7.Data Storage

We retain your personal data only for as long as necessary to provide you with products and services and to fulfill legitimate and fundamental business purposes. We retain data under the following circumstances:

• Data is retained until you delete it. You have the right to request that we delete certain of your personal data.

• We have set data retention periods so that certain data expires or is deleted after specific timeframes.

• We retain your account data based on the scope of your authorization until your personal account is deleted.

• After your account is deleted, we may retain certain data for a longer period, but only for very limited purposes, such as fulfilling legal obligations.

8.Cross-Border Data Transfers

Due to the global nature of our business, we share personal data internationally with MakeRoad affiliated companies and partners when carrying out the data processing activities described in this Policy. Whenever we transfer personal data internationally, we ensure that the data transfer complies with applicable law (e.g., Article 45 GDPR, Article 46 GDPR).

9.Protecting the Security of Your Personal Information

We attach great importance to the security of your personal information. To ensure the security of your information, we have taken the following measures:

• We take all reasonable measures to ensure the minimization of the scope of personal information collection and do not collect personal information unrelated to the purpose. We also only retain your personal information for the period required for the purposes stated in this Policy, unless required by law or due to changes in authorization.

• We use necessary security technical measures to ensure the confidentiality of data transmission and storage; simultaneously, we establish reliable protection mechanisms to prevent data and the servers storing data from suffering malicious attacks.

• We establish access control mechanisms to ensure that only authorized personnel can access personal information.

If the aforementioned mechanisms and facilities are compromised, leading to data information leakage that damages your legitimate rights and interests, we will promptly disclose information as required by laws and regulations, assume legal liability, and handle and report the incident to regulatory authorities as required.

10.Protection of Minors' Information

Minors should use our products or services under the supervision of a parent or guardian. We do not directly provide services to children under the age of 14. If you are a guardian and discover that a child has registered or provided relevant personal information, please contact us at official@makeroad.com to have this information deleted.

11.Data Retention Period

Generally, we only retain your personal information for the shortest time necessary to achieve the purposes for which you have given consent, unless otherwise provided by laws and regulations or you have provided separate consent. After the retention period expires, we will delete or anonymize your personal information.

If you apply to delete your account, the relevant account information will be deleted or anonymized within 30 days after account deletion.

12.Policy Updates

We may update this Privacy Policy based on legal and regulatory requirements, as well as business and technological changes. If this Policy undergoes significant changes, we will notify you via a prominent notice on our website and obtain your consent for new processing purposes via station message or pop-up.

13.Contact Information

Company Name: MAKEROAD HONG KONG HOLDINGS LIMITED

Address: UNIT D18B 3 / F WONG KING INDUSTRIAL BUILDING NO 2-4 TAI YAU STREET HK

Email: official@makeroad.com