Effective date: September 8, 2026

1. Scope and who we are

This Privacy Policy explains how 朝輝國際股份有限公司, whose registered English company name is LEADEX & CO. ("Leadex," "we," "us," or "our"), collects, uses, discloses, retains, and protects personal information through www.leadexco.com and communications that begin through the website (collectively, the "Site").

Leadex is a Taiwan company and operates the Site from Taiwan. Leadex is not registered as a company in the United States. Gaia Material LLC is a separate California company that may assist with U.S. inquiries and related business support. Gaia may receive only the information reasonably needed for those services.

This Policy applies to information about identifiable individuals. It does not apply to information that is lawfully anonymized or aggregated so that it cannot reasonably identify an individual. Separate contracts or notices may apply to customers, suppliers, employees, job applicants, and other relationships.

2. Personal information we collect

Information you provide

• Contact and professional information, such as company name, first and last name, job title or position, business email address, telephone number, and preferred contact method.

• Inquiry information, such as the subject of your request; desired product type, composition, color, quantity, intended use, target price, delivery location, specifications, certifications, and other information you choose to submit.

• Newsletter information, such as your email address, subscription status, and communication preferences.

• Business communications and transaction-related information, such as correspondence, meeting notes, quotation and sample requests, order references, delivery information, and customer-service records when your relationship begins through the Site.

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Information collected automatically

• Device and network information, such as Internet Protocol address, browser type, operating system, device type, language, and general location derived from an IP address.

• Usage information, such as pages viewed, links selected, search terms, referring and exit pages, dates and times of visits, and interactions with Site features.

• Cookie and similar-technology information, such as identifiers, consent choices, session information, and security or performance logs. See the Cookie Policy below for more information.

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Information from other sources

• We may receive business contact information from suppliers, service providers, trade-show contacts, referrals, publicly available business sources, or the company for which you work. When Taiwan law requires notice for indirectly collected information, we will provide it no later than the time of first use unless an exception applies.

• Please do not submit sensitive information. The Site is not designed to collect government identification numbers, financial account credentials, health information, biometric information, or other sensitive personal data. Do not include such information in a free-text inquiry.

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3. Why we use personal information​

 

• Respond to inquiries, identify suitable materials, prepare quotations, arrange samples, and communicate about products, orders, delivery, or partnerships.

• Route U.S. inquiries to Gaia Material LLC and route technical or sourcing questions to relevant employees, mills, suppliers, logistics providers, or professional advisers where necessary.

• Send newsletters, product updates, event invitations, or other marketing communications when permitted by law and according to your choices.

• Operate, maintain, personalize, troubleshoot, and secure the Site; prevent fraud and misuse; and analyze Site performance.

• Maintain business records, enforce agreements, protect our rights and those of others, comply with legal obligations, and respond to lawful requests from authorities.

• Support a corporate transaction, such as a merger, financing, reorganization, or sale of all or part of a business, subject to appropriate confidentiality and legal safeguards.

4. Taiwan Personal Data Protection Act notice

For information collected directly from you, this section is intended to provide the notice described in Article 8 of Taiwan's Personal Data Protection Act (PDPA).

 

• Collector: 朝輝國際股份有限公司 (LEADEX & CO.); information may also be handled by Gaia Material LLC and service providers acting for Leadex.

• Purposes: Business inquiries, customer and supplier relationship management, quotations, samples, order and delivery support, marketing with choice, website operations and security, analytics, recordkeeping, and legal compliance.

• Categories: Identity and contact details; professional and company information; inquiry and communication content; commercial and transaction information; device, network, usage, cookie, and security data.

• Period: For the periods described in Section 8, while a business relationship remains active, and for any longer period required or permitted by law.

• Territory: Taiwan, the United States, and other locations where our service providers, suppliers, or professional advisers operate.

• Recipients: Leadex personnel; Gaia Material LLC; Wix and other hosting, email, CRM, analytics, security, logistics, and professional service providers; relevant mills or suppliers; authorities or transaction counterparties when legally necessary.

• Methods: Electronic and paper records; email, phone, messaging, forms, CRM systems, analytics tools, and other reasonable business methods.

• Your rights: You may inquire about or review your personal data, request a copy, request correction or supplementation, request cessation of collection/processing/use, and request erasure, subject to applicable exceptions.

• If you do not provide data: You may browse most public pages without submitting a form. If required contact or inquiry details are not provided, we may be unable to respond, prepare a quotation, arrange a sample, or provide requested services.

5. Cookies, analytics, and online tracking

The Site uses cookies and similar technologies needed for security, stability, forms, session management, and performance. We may also use functional or analytics technologies where enabled and permitted by law. Where consent is required, non-essential technologies should remain disabled until you make a choice through the cookie banner.

Some browsers offer a Do Not Track signal. Because there is not a universally accepted standard for interpreting this signal, the Site does not currently respond to legacy Do Not Track signals. Where required by applicable law, we will recognize legally valid browser-based opt-out preference signals, such as Global Privacy Control, for the browser or device sending the signal.

Third parties may collect information through technologies they provide to the Site, subject to our configuration and their own privacy terms. Please review the Cookie Policy for categories, examples, and choices.

6. How we disclose personal information

We may disclose personal information to the following categories of recipients for the purposes described above:

 

• Gaia Material LLC, a separate California company, when reasonably needed for U.S. sales support, customer service, samples, logistics, or administration.

• Service providers that host or support the Site, forms, email, newsletters, customer records, analytics, security, data storage, professional advice, and related business functions. Wix is the current website platform provider.

• Mills, suppliers, laboratories, logistics providers, and other business partners when reasonably necessary to evaluate a request, provide a quotation or sample, verify a specification, fulfill an order, or support delivery. We seek to limit the information shared to what is needed.

• Government agencies, courts, regulators, law enforcement, or other parties when required by law or reasonably necessary to protect rights, safety, property, systems, or users.

• Prospective or completed transaction counterparties and advisers in connection with a merger, financing, restructuring, acquisition, or sale, subject to appropriate safeguards.

We do not sell personal information for monetary consideration. We do not intentionally use personal information collected through the Site for cross-context behavioral advertising. If these practices change, we will update this Policy and provide any notice or opt-out mechanism required by law.

7. International transfers

Because Leadex is based in Taiwan, Gaia Material LLC is based in the United States, and service providers and commercial partners may operate in other jurisdictions, personal information may be transferred to and processed outside the place where it was collected. Privacy laws in those locations may differ. We use reasonable contractual, organizational, and technical safeguards appropriate to the information and the transfer and comply with applicable restrictions on cross-border transfers.

8. Retention

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• General inquiry and prospect records are ordinarily retained for up to five years after the last substantive interaction, unless a shorter period is appropriate or a longer period is needed for an active relationship, dispute, legal obligation, or legitimate business record.

• Customer, supplier, quotation, order, shipping, tax, accounting, and compliance records are retained for the period required by applicable law and normal business recordkeeping requirements.

• Newsletter subscription information is retained until you unsubscribe or we stop the program. We may retain a minimal suppression record so that we can honor an opt-out.

• Cookie and log information is retained according to the applicable technology, security need, and the periods described in the Cookie Policy or the provider's current settings.

We may delete, anonymize, or aggregate information earlier when it is no longer needed.

9. Security

We use reasonable administrative, technical, and physical measures designed to protect personal information against unauthorized access, loss, alteration, disclosure, or destruction. No website, email system, or storage method can be guaranteed to be completely secure. Please do not send confidential technical information or sensitive personal data through the Site unless we have agreed on an appropriate secure method.

10. Your choices and rights

Marketing choices

• You may unsubscribe from marketing emails by using the unsubscribe link in the message or by emailing sales@leadexco.com. We may still send non-marketing communications needed for an inquiry, order, safety notice, or existing business relationship.

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Data rights

• Depending on where you live, you may have rights to request access to or a copy of personal information, correction, deletion, restriction or cessation of processing, objection to marketing, portability, or information about collection and disclosure. You may also have the right to appeal a refusal or complain to a regulator.

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To exercise a right, email sales@leadexco.com with the subject Privacy Request, or use https://www.leadexco.com/contact-us and enter Privacy Request as the subject. You may also write to the Taiwan address in Section 15. We may need to verify your identity and authority before completing a request. We will not discriminate against you for exercising a legal privacy right.

11. California disclosures

California's Online Privacy Protection Act requires certain disclosures for commercial websites that collect personally identifiable information from California residents. The categories of information we collect, categories of third parties to whom we may disclose it, and the methods for requesting review or correction are described in this Policy. The effective date appears above, and Section 5 explains our response to online tracking signals.

If and to the extent the California Consumer Privacy Act, as amended, applies to Leadex's processing, California residents may have rights to know or access, correct, delete, and receive information about covered disclosures; to opt out of sale or sharing; to limit certain uses of sensitive personal information; and to receive equal service and pricing. Leadex does not currently sell personal information or intentionally use Site information for cross-context behavioral advertising. Submit a Privacy Request as described in Section 10.

12. Children

The Site is intended for business users and is not directed to children under 16. We do not knowingly collect personal information from children through the Site. If you believe a child has provided personal information, please submit a Privacy Request so we can review and, where appropriate, delete it.

13. Third-party sites and services

The Site may link to social networks, messaging services, videos, supplier sites, or other third-party services. Their privacy practices are governed by their own notices. A link does not mean that Leadex controls or endorses the third party's privacy or security practices.

14. Changes to this Policy

We may update this Policy to reflect changes in law, technology, vendors, or our practices. We will post the revised version on the Site and update the effective date. If required by law, we will provide additional notice or obtain consent.

15. Contact us

Email: sales@leadexco.com (subject: Privacy Request)

Online: Submit a message at https://www.leadexco.com/contact-us with the subject Privacy Request.

Taiwan operator: 朝輝國際股份有限公司 (LEADEX & CO.), 1F., No. 306, Chang'an W. Rd., Datong Dist., Taipei City 103012, Taiwan (R.O.C.); 臺北市大同區長安西路306號1樓. Telephone: +886-2-2793-3377.

U.S. service contact: Gaia Material LLC, 530 Technology Dr., Suite 100, Irvine, CA 92618, USA.