Privacy Policy

1. Information We Collect

1.1 Information You Provide Directly

When you use our services, website, or mobile applications, you may provide us with:

• Personal identification information (name, email address, phone number, postal address)
• Business information (company name, job title, industry)
• Account credentials (username, password)
• Payment information (credit card details, billing address)
• Communication data (messages, inquiries, feedback)
• Profile information and preferences

1.2 Information Collected Automatically

When you access our services, we may automatically collect:

• Device information (device type, operating system, unique device identifiers)
• IP address and location data
• Browser type and version
• Usage patterns and behavioral data
• Cookies and similar tracking technologies
• App performance data and crash reports

1.3 Information from Third Parties

We may receive information from:

• Business partners and service providers
• Advertising networks and analytics providers
• Social media platforms (when you connect or interact with us)
• Public databases and data providers

2. GDPR Compliance (European Union)

If you are located in the European Economic Area (EEA), this section applies to you. Guangzhou Geluming Trading Co., Ltd processes personal data in accordance with the General Data Protection Regulation (GDPR).

2.1 Legal Basis for Processing

We process your personal data under the following legal bases:

• Consent: You have given clear consent for us to process your personal data for specific purposes
• Contract: Processing is necessary for a contract we have with you
• Legal Obligation: Processing is necessary for us to comply with the law
• Legitimate Interests: Processing is necessary for our legitimate interests, provided your interests and fundamental rights do not override those interests

2.2 Data Subject Rights under GDPR

If you are in the EEA, you have the right to:

• Right of Access: Obtain confirmation of whether we process your data and access your personal data
• Right to Rectification: Have inaccurate personal data corrected
• Right to Erasure: Request deletion of your personal data ("right to be forgotten")
• Right to Restrict Processing: Request limitation of processing activities
• Right to Data Portability: Receive your data in a structured, commonly used format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent
• Right to Lodge Complaint: File a complaint with a supervisory authority

2.3 Supervisory Authority

You have the right to lodge a complaint with the data protection authority in your country. For EU member states, contact information for local supervisory authorities is available at: EDPB Members

3. US Privacy Laws (CCPA/CPRA)

If you are a California resident, this section applies to you. Guangzhou Geluming Trading Co., Ltd complies with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

3.1 Categories of Personal Information We Collect

• Identifiers: Name, email, phone, address, IP address, device identifiers
• Commercial Information: Purchase history, transaction records, product preferences
• Internet Information: Browsing history, interaction with our website and apps
• Geolocation Data: Physical location based on IP or device data
• Professional Information: Job title, company, industry
• Inferred Data: Preferences, characteristics, behavior patterns

3.2 Your California Privacy Rights

As a California resident, you have the right to:

• Know: Request disclosure of personal information collected, used, shared, or sold
• Delete: Request deletion of your personal information
• Opt-Out: Opt-out of the sale or sharing of your personal information
• Non-Discrimination: Not be discriminated against for exercising your privacy rights
• Correct: Request correction of inaccurate personal information
• Limit Use: Limit use of sensitive personal information

3.3 Other US State Privacy Laws

We also comply with privacy laws in other US states, including but not limited to:

• Virginia Consumer Data Protection Act (VCDPA)
• Colorado Privacy Act (CPA)
• Connecticut Data Privacy Act (CTDPA)
• Utah Consumer Privacy Act (UCPA)
• Texas Data Privacy and Security Act (TDPSA)
• Florida Privacy Protection Act (FPPA)
• Other applicable state privacy laws

4. COPPA Compliance (Children's Privacy)

Guangzhou Geluming Trading Co., Ltd complies with the Children's Online Privacy Protection Act (COPPA) and takes children's privacy seriously.

4.1 Age Restriction

• Our services and applications are not directed to children under 13 years of age
• We do not knowingly collect personal information from children under 13
• If we become aware of collecting data from a child under 13, we will take immediate steps to delete such information

4.2 Parental Rights

Parents and guardians have the right to:

• Review personal information collected from their children
• Request deletion of their children's personal information
• Refuse further collection or use of their children's information
• Consent to collection without consenting to third-party disclosure

4.3 International Children's Privacy

We also comply with children's privacy requirements in other jurisdictions:

• UK: Age Appropriate Design Code (AADC)
• EU: GDPR provisions for children
• Australia: Privacy Act and Online Safety requirements
• Canada: Personal Information Protection and Electronic Documents Act (PIPEDA)

5. PIPA Compliance (Korea)

If you are located in South Korea, we comply with the Personal Information Protection Act (PIPA) and related regulations.

5.1 Information We Collect from Korean Users

In accordance with PIPA, we collect only the minimum personal information necessary and inform users of:

• Purpose of collection
• Items of information collected
• Period of retention and use
• Method of destruction

5.2 Rights of Korean Data Subjects

Under PIPA, you have the right to:

• Access your personal information
• Correct errors in your personal information
• Request deletion of your personal information
• Suspend processing of your personal information
• Withdraw consent

5.3 Korean Data Protection Commission

You may file a complaint with the Personal Information Protection Commission (PIPC) at: www.pipc.go.kr

6. PIPL Compliance (China)

For users in China, we comply with the Personal Information Protection Law (PIPL) of the People's Republic of China.

6.1 Lawful Basis for Processing

We process personal information based on:

• Consent of the individual
• Necessity for performance of contract
• Necessity for compliance with legal obligations
• Necessity for protecting vital interests
• Necessity for public health or emergency situations

6.2 Individual Rights under PIPL

• Right to Know: Be informed of processing activities
• Right to Decide: Exercise control over your personal information
• Right to Request: Access and copy your personal information
• Right to Correct: Correct inaccurate personal information
• Right to Delete: Request deletion under certain circumstances
• Right to Transfer: Receive your information in portable format
• Right to Refuse: Refuse automated decision-making in certain cases

6.3 Sensitive Personal Information

We obtain separate consent before processing sensitive personal information, including:

• Biometric data
• Medical and health data
• Financial accounts
• Location tracking
• Data from minors

7. Advertising & Third-Party Ad Networks

Our mobile applications include advertising provided by third-party advertising networks and platforms. This section explains how we use advertising technologies and the choices available to you.

7.1 How Advertising Works

We use third-party advertising technologies that collect and use information to display relevant advertisements. These technologies may include:

• Device identifiers and advertising IDs
• Cookies and similar tracking technologies
• Pixel tags and web beacons
• SDK integration for mobile advertising
• Cross-device tracking and targeting
• Behavioral profiling and audience segmentation

7.2 Purpose of Advertising

We use advertising to:

• Support the free or low-cost delivery of our services
• Provide relevant advertisements based on your interests
• Measure the effectiveness of advertising campaigns
• Generate revenue to maintain and improve our applications

7.3 Your Advertising Choices

You can control advertising personalization and opt-out of certain advertising tracking through:

• Device Settings: Reset or limit advertising identifiers in your device settings
• App Settings: Use opt-out options within our applications
• Industry Programs: Use industry opt-out tools like DAA WebChoices or AppChoices
• Platform Settings: Use Google AdSettings and similar platform tools

8. Advertising Platforms We Use

Our applications integrate with the following advertising platforms and networks to serve advertisements:

8.1 Major Ad Networks and Platforms

• Google AdMob: Google's mobile advertising platform providing in-app advertising solutions
• Facebook Audience Network (FAN): Facebook's advertising network for mobile applications
• Unity Ads: Unity Technologies' advertising platform for mobile games and apps
• AppLovin: Mobile advertising and monetization platform
• ironSource: Mobile app monetization and advertising platform
• Vungle (by Liftoff): In-app advertising platform specializing in video ads
• Chartboost: Mobile game advertising and monetization platform
• MoPub (by AppLovin): Mobile ad exchange and programmatic platform
• InMobi: Global mobile advertising and monetization platform
• Liftoff Monetize: Mobile app advertising and monetization platform
• Pangle: ByteDance's global mobile advertising platform
• Mintegral: Cross-platform mobile advertising platform
• Appodeal: Programmatic advertising platform for mobile apps
• Start.io: Mobile audience and advertising platform
• AdColony: Mobile video advertising platform

8.2 Ad Network Compliance

All advertising platforms we use are required to comply with:

• Applicable privacy laws and regulations
• Industry standards and best practices
• Platform policies (Google Play, App Store)
• User consent requirements
• Data security and protection standards

8.3 Data Sharing with Ad Networks

When you use our applications, advertising networks may collect:

• Device information (device ID, type, OS version)
• Advertising identifier (GAID, IDFA)
• Location data (country, region, city)
• App usage and behavioral data
• IP address and network information

This information is used by ad networks to deliver targeted advertisements and measure ad performance.

9. Types of Ads in Our Applications

Our mobile applications may display the following types of advertisements:

9.1 Splash Ads (Opening Ads)

Splash ads appear when you first open the application or return to it after a period of inactivity. These full-screen advertisements:

• Display for a short duration (typically 3-5 seconds)
• Can usually be skipped or closed after a few seconds
• Generate revenue to support free application features
• May be personalized based on your interests and device data

9.2 Rewarded Video Ads (Incentivized Ads)

Rewarded video ads offer you the opportunity to earn rewards in exchange for watching advertisements:

• Provide virtual currency, items, or premium features
• Are typically 15-30 second video advertisements
• Require voluntary opt-in viewing
• Cannot be skipped and must be watched in full for the reward

9.3 Interstitial Ads

Interstitial ads appear at natural transition points in the application:

• Display between levels, screens, or content sections
• Are full-screen advertisements that cover the interface
• Can usually be closed after a countdown timer
• May include images, videos, or interactive content

9.4 Banner Ads

Banner ads are displayed continuously within the application interface:

• Appear at the top or bottom of the screen
• Refresh periodically with new advertisements
• Allow continued app usage while viewing
• Can be hidden in some premium versions

10. Data Security

Guangzhou Geluming Trading Co., Ltd implements appropriate technical and organizational measures to protect your personal information, including:

• Encryption of data in transit using TLS/SSL
• Encryption of sensitive data at rest
• Access controls and authentication measures
• Regular security assessments and audits
• Employee training on data protection
• Incident response and breach notification procedures
• Vendor security assessment requirements

11. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law.

11.1 Retention Periods

• Account Information: Retained while your account is active and for 3 years after closure
• Transaction Data: Retained for 7 years for legal and tax compliance
• Communication Records: Retained for 3 years after the communication
• Marketing Preferences: Retained until you withdraw consent
• Usage Data: Retained for 2 years for analytics purposes

11.2 Data Deletion

When personal information is no longer needed or when you request deletion, we will:

• Delete or anonymize the data in accordance with our procedures
• Notify any third parties with whom we shared the data
• Retain limited information as required by law

12. Your Rights

Regardless of your location, you have certain rights regarding your personal information:

• Access your personal information
• Correct inaccurate or incomplete information
• Request deletion of your information
• Object to processing of your information
• Withdraw consent where processing is based on consent
• Receive your data in a portable format
• Lodge a complaint with your local data protection authority

13. International Data Transfers

Your personal information may be transferred to and processed in countries other than your country of residence, including China where our company is based. When we transfer data internationally, we ensure appropriate safeguards are in place:

• Standard Contractual Clauses (SCCs) approved by relevant authorities
• Binding Corporate Rules for intra-group transfers
• Certification mechanisms and codes of conduct
• Explicit consent where required

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, or legal requirements. We will notify you of material changes by:

• Posting the updated policy on our website
• Updating the "Last Updated" date
• Sending notification through our applications or email
• Requesting renewed consent where required

We encourage you to review this policy periodically to stay informed about our privacy practices.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Guangzhou Geluming Trading Co., Ltd

Room A15, 3A03, No. 5 Jianzhong Road,
Zhongshan Avenue, Tianhe District,
Guangzhou, 510000, CN

Business Support: support@gelvming.com
Key Accounts: tianyongming@gelvming.com

Data Protection Officer

For privacy-related inquiries, you may also contact our Data Protection Officer at: privacy@gelvming.com

This Privacy Policy was last updated on June 15, 2024 and is effective immediately. Previous versions are available upon request.