Privacy Policy

Effective Date: January 1, 2026  |  Last Updated: July 31, 2026

Version 1.0

Summary: LSM ("we", "us", "the Platform") is a B2B marketplace connecting European buyers with verified LED and digital signage suppliers worldwide. We take your privacy seriously. This policy explains what data we collect, why we collect it, how we protect it, and what rights you have. We comply with both the EU General Data Protection Regulation (GDPR) and the People's Republic of China Personal Information Protection Law (PIPL).

1. Data Controller

The data controller responsible for your personal data is:

  • Company: LSM Platform
  • Contact Email: privacy@lsm-platform.eu
  • Platform URL: /

If you have any questions about how we handle your data, or if you wish to exercise any of your rights described in this policy, please contact us at the email above.

2. What Personal Data We Collect

We collect personal data that you provide directly to us when you register, use our platform, or communicate with other users. The categories of data are described below.

2.1 Account Registration Data

When you create an account as a buyer or supplier, we collect:

  • Identity data: Full name of the contact person, company name
  • Contact data: Email address, phone number, WeChat ID, WhatsApp number (all optional except email)
  • Business data: Tax ID / VAT number, company registration country, website, headquarters address
  • Security data: Password (stored as a bcrypt hash — never in plain text)
2.2 Supplier-Specific Data

If you register as a supplier, we additionally collect:

  • Product specialization categories and subcategories
  • Shipping origin, supported shipping regions, warehouse locations
  • Supported Incoterms (FOB, CIF, DDP, EXW, etc.)
  • Business certificates, ISO certifications, and other verification documents
  • Company description and product portfolio
  • Subscription plan selection (FREE, PRO, ENTERPRISE)
2.3 Buyer-Specific Data

If you register as a buyer, we additionally collect:

  • RFQ (Request for Quotation) details: project description, technical specifications, quantities, budget, delivery requirements
  • Preferred supplier criteria (minimum rating, trust score, EU experience, etc.)
  • Privacy preferences (option to hide contact details from suppliers)
2.4 Transaction and Communication Data
  • Bids and pricing submitted by suppliers in response to RFQs
  • Messages, files, images, and documents exchanged through the platform chat system
  • Service orders (LED installation, legal review, inspections, negotiation agency)
  • Payment records and transaction history
  • Winner selections and deal outcomes
2.5 Technical and Usage Data
  • IP address (for security and fraud prevention)
  • Browser type and version, device type, operating system
  • Login timestamps, session duration, page views
  • Referring URL (how you arrived at the platform)
2.6 Manager Staff Data

If you are assigned as a platform Manager, we additionally collect:

  • Full name, email, phone number
  • Language proficiencies and specialization areas
  • Activity logs: messages sent, chats handled, response times

3. Legal Basis for Processing (GDPR)

Under the GDPR, we process your personal data only when we have a valid legal basis. The applicable bases are:

PurposeLegal Basis
Account creation and managementPerformance of a contract (Art. 6(1)(b))
Facilitating RFQs, bids, and supplier-buyer matchingPerformance of a contract (Art. 6(1)(b))
Chat communication between usersPerformance of a contract (Art. 6(1)(b))
Sending platform notifications and alertsLegitimate interest (Art. 6(1)(f))
Supplier verification and qualification reviewLegitimate interest (Art. 6(1)(f))
Fraud prevention and platform securityLegitimate interest (Art. 6(1)(f))
Complying with legal obligationsLegal obligation (Art. 6(1)(c))
Analytics and service improvementLegitimate interest (Art. 6(1)(f)) — anonymized data only

Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.

4. Legal Basis for Processing (PIPL)

If you are located in the People's Republic of China, the PIPL requires us to inform you of the following:

PurposeLegal Basis
Account creation and managementNecessary for contract performance
RFQ, bid, and matching servicesNecessary for contract performance
Chat communicationNecessary for contract performance
Platform notificationsNecessary for service provision
Supplier verificationNecessary to ensure service quality
Security and fraud preventionNecessary to protect platform security
Legal complianceRequired by law

Under the PIPL, you have the right to withdraw consent at any time. We will process your personal information only within the scope and for the purposes you have consented to.

5. Contact Confidentiality — Our Core Privacy Feature

Your contact details are confidential by default. LSM never reveals your personal contact information (email, phone, WeChat, WhatsApp) to other platform users unless you explicitly choose to share it.
5.1 During the Bidding Process
  • Suppliers submit bids anonymously — buyers see "Supplier #1", "Supplier #2", etc. Company names, emails, and phone numbers are hidden.
  • Buyer contact details are hidden from suppliers at all times during the bidding process.
  • Only technical specifications, pricing, delivery terms, and Incoterms are visible to both parties.
5.2 After Winner Selection
  • When a buyer selects a winning bid, the supplier's company name and email become visible to the buyer.
  • However, the buyer's contact details remain hidden unless the buyer explicitly chooses to reveal them.
  • All communication continues through the platform's built-in encrypted chat system.
5.3 "Hide My Contacts" Feature
  • Buyers can enable "Hide my contact details" in their profile settings.
  • When enabled, the buyer's email and phone number are never shown to any supplier — even after a winner is selected.
  • All communication happens exclusively through the platform chat, ensuring complete privacy.
  • The buyer controls this setting at any time and can change it from their profile.
5.4 Manager-Assisted Communication
  • Platform Managers facilitate negotiations between buyers and suppliers without exposing personal contact details.
  • Managers communicate through the platform chat and can translate messages between languages.
  • Manager access to user data is limited to what is necessary for facilitating the negotiation.

6. How We Use Your Data

We use your personal data for the following specific purposes:

  • Platform Operations: Processing RFQ submissions, managing bids, matching buyers with suppliers, facilitating chat communication, and delivering requested services.
  • Account Management: Creating and maintaining your account, verifying supplier qualifications, managing subscriptions, and sending account-related notifications.
  • Communication: Sending bid alerts, chat message notifications, tender updates, service confirmations, and platform announcements. You may opt out of non-essential notifications in your settings.
  • Security and Fraud Prevention: Detecting unauthorized access, preventing fraudulent activity, verifying identities, and protecting platform integrity.
  • Legal Compliance: Fulfilling tax reporting obligations, responding to lawful requests from authorities, and maintaining records as required by applicable law.
  • Service Improvement: Analyzing anonymized and aggregated usage patterns to improve platform features, user experience, and service quality. We do not use individual-level data for this purpose.
  • Payment Processing: Processing subscription payments and service orders through our payment partners.

7. Data Storage and Security

We take the security of your data seriously and implement the following measures:

  • Encryption: All data is transmitted over encrypted connections (HTTPS/TLS 1.2+). Sensitive data at rest is encrypted using AES-256.
  • Password Security: Passwords are hashed using bcrypt (PHP password_hash with default cost). We never store, log, or have access to your plain-text password.
  • Access Control: Platform data is accessible only to authorized personnel. Manager access is limited to chats assigned to them. Admin access is logged and audited.
  • File Storage: Chat files, documents, and uploaded certificates are stored in access-controlled directories with restricted permissions.
  • Regular Backups: Database backups are performed regularly and stored in secure, encrypted locations.
  • Security Audits: We conduct periodic security reviews and vulnerability assessments.
  • Data Retention: Personal data is retained for as long as your account is active, or as required by law (typically 7 years for financial records under EU tax law). Upon account deletion, personal data is permanently removed within 30 days, except where retention is legally required.
  • Breach Notification: In the event of a data breach that poses a high risk to your rights, we will notify you and the relevant supervisory authority within 72 hours, as required by GDPR Art. 33.

8. Data Sharing and Third Parties

We do NOT sell, rent, trade, or share your personal data with third parties for their marketing purposes. Period.

Your data may be shared only in the following limited circumstances:

  • With Your Consent: When you explicitly choose to share contact details with a counterparty (e.g., after selecting a winner and choosing to reveal your email).
  • Service Providers: We use trusted third-party services for hosting, payment processing, email delivery, and translation. These providers are bound by strict data processing agreements (DPAs) and are permitted to process your data only for the specific purposes we define.
  • Legal Requirements: We may disclose your data if required by law, court order, regulatory authority, or legal process. We will notify you of such requests unless legally prohibited.
  • Business Transfer: In the event of a merger, acquisition, or sale of assets, your data may be transferred with prior notice to all affected users. You will have the opportunity to delete your account before any such transfer.

International Data Transfers: When data is transferred outside the EU/EEA (e.g., to suppliers in China), we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the European Commission, or adequacy decisions where applicable.

9. Your Rights Under GDPR (EU/EEA Users)

If you are located in the European Economic Area, you have the following rights under the General Data Protection Regulation:

RightDescription
Right of Access (Art. 15)Request a copy of all personal data we hold about you, including the purposes of processing, categories of data, and recipients.
Right to Rectification (Art. 16)Request correction of inaccurate or incomplete personal data without undue delay.
Right to Erasure (Art. 17)Request deletion of your personal data ("right to be forgotten") when the data is no longer necessary, consent is withdrawn, or processing is unlawful.
Right to Restrict Processing (Art. 18)Request limitation of how we process your data in certain circumstances (e.g., during accuracy disputes).
Right to Data Portability (Art. 20)Receive your personal data in a structured, commonly used, machine-readable format (JSON/CSV) and transmit it to another controller.
Right to Object (Art. 21)Object to processing based on legitimate interests, including direct marketing. We will cease processing unless we demonstrate compelling legitimate grounds.
Right to Withdraw Consent (Art. 7(3))Withdraw consent at any time where processing is based on consent. Withdrawal does not affect the lawfulness of processing before withdrawal.
Right Not to Be Subject to Automated Decision-Making (Art. 22)You have the right not to be subject to decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects.

How to Exercise Your Rights:

  • Email us at: privacy@lsm-platform.eu
  • We will respond to your request within 30 days (extendable by 60 days for complex requests, with notification).
  • We may ask you to verify your identity before processing your request.
  • You have the right to lodge a complaint with your local Data Protection Authority (DPA) if you believe your rights have been infringed.

10. Your Rights Under PIPL (China Users)

If you are located in the People's Republic of China, you have the following rights under the Personal Information Protection Law (PIPL):

RightPIPL ArticleDescription
Right to Be InformedArt. 17Right to know how your personal information is processed, including the purpose, method, and scope of processing.
Right to DecideArt. 44Right to restrict or refuse the processing of your personal information.
Right to Access and CopyArt. 45Right to access your personal information and obtain copies from the personal information handler.
Right to CorrectionArt. 46Right to request correction of inaccurate or incomplete personal information.
Right to DeletionArt. 47Right to request deletion of personal information when the purpose has been achieved, the service is terminated, or processing is unlawful.
Right to Data PortabilityArt. 45Right to request transfer of your personal information to a personal information handler designated by you, where conditions are met.
Right to Withdraw ConsentArt. 15Right to withdraw consent at any time. The handler must provide a convenient way to withdraw consent.
Right to Refuse Automated Decision-MakingArt. 24Right to refuse decisions made solely by automated processing that have a significant impact on your rights.

Cross-Border Data Transfer: When transferring personal information outside of China, PIPL requires that we:

  • Obtain your separate consent for cross-border transfers
  • Conduct a personal information protection impact assessment
  • Ensure the overseas recipient provides adequate protection
  • Inform you of the overseas recipient's identity, contact details, purpose, and methods of processing

How to Exercise Your Rights:

  • Email us at: privacy@lsm-platform.eu
  • We will respond within 15 working days as required by PIPL.

11. Cookies and Tracking

We use only essential cookies required for platform functionality:

  • Session cookies: To maintain your login session and security state.
  • CSRF tokens: To prevent cross-site request forgery attacks.
  • Language/currency preferences: To remember your display preferences.

We do NOT use advertising cookies, analytics tracking cookies, third-party tracking pixels, or any form of behavioral advertising. We do not sell cookie data to third parties.

You can manage or disable cookies through your browser settings. Note that disabling essential cookies may prevent you from using the platform.

12. Children's Privacy

LSM is a B2B platform intended for business professionals. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that we have collected data from a minor, we will delete it immediately.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or platform features.

  • Material changes will be notified to all registered users via email and/or platform notification at least 30 days before they take effect.
  • The "Last Updated" date at the top of this page indicates when the policy was last revised.
  • Continued use of the platform after the effective date constitutes acceptance of the updated policy.
  • If you disagree with the updated policy, you may delete your account before the changes take effect.

14. Contact Us

For any questions, concerns, or requests related to this Privacy Policy or your personal data:

General Inquiriesinfo@lsm-platform.eu
Privacy & Data Protectionprivacy@lsm-platform.eu
Legal & Compliancelegal@lsm-platform.eu
Data Protection Officerdpo@lsm-platform.eu
Platform URL/