1 Introduction

2 Information We Collect

(1) Personal Identity Information

Registration Information: When you register an account, you may voluntarily provide us with your name, email address, and avatar (optional information). This information is used to create your exclusive account and ensure you can log in smoothly and enjoy our Services.

Third-Party Account Login Information: If you choose to log in using third-party accounts (such as Google, Apple ID), we will obtain basic information authorized and shared by the third-party account, such as nickname and email address. The specific information obtained will be as indicated on the third-party authorization page. This method aims to provide you with a convenient login experience and reduce the registration process. We only use this information to create associated accounts in our Services and enable quick login functionality.

(2) Divination-Related Information

Actively Input Content: Content you actively input during divination, including divination questions (such as "relationship development," "financial planning," etc.) and selected card spreads, which are the core basis for generating divination interpretations. We maintain strict confidentiality and only use this information to provide you with accurate divination services.

Dialogue and Feedback Records: Dialogue records with AI fortune tellers and your feedback on divination results also fall within the category of sensitive personal information. We collect this information to improve divination interpretation content, provide services that better meet your needs, and facilitate your subsequent viewing of historical records to review divination processes and results. This information will not be used for any purposes unrelated to divination services.

(3) Device and Usage Information

Device Information: To ensure normal operation and optimization of services, we automatically collect your device information, including IP address, device model, operating system version, unique device identifiers (such as IDFV for iOS, AAID for Android), network status, etc. This information helps us adapt to different devices and resolve potential compatibility issues, such as optimizing the APP's display effects or functional stability for specific device models.

Usage Data: We also collect relevant data during your use of the APP, such as APP open/close times, types of card decks browsed, divination frequency, function click records (such as the number of clicks on the "re-divine" button), etc. By analyzing this data, we can understand user behavior patterns to optimize service performance, such as adjusting the position of frequently clicked functions in the interface to improve user operation convenience; optimizing the display priority of popular card spreads based on browsing popularity of different card decks to provide services that better match user interests.

3 Purpose of Information Use

(1) Providing Core Services

• Divination Interpretation Generation: Based on your input divination questions and related information, we use professional divination algorithms and models to generate accurate and personalized divination interpretation content for you.
• History Record Storage: Store your divination history records for convenient access to past divination situations at any time, review interpretation results and personal development trajectory, providing you with a continuous service experience.
• Notification Services: Send divination report notifications through your provided contact information (such as email), for example, informing you "Your daily fortune has been generated," ensuring you can timely obtain your divination information.

(2) Improving Service Quality

• Interpretation Model Optimization: In-depth analysis of common themes in divination content, such as statistics on "proportion of emotional questions" and "concentrated demands of career questions," using this as a basis to optimize divination interpretation models, improve interpretation accuracy and targeting, and better meet your needs.
• Function Adaptation: Based on collected device information, adapt and optimize APP functions for different operating system versions and device models. For example, optimizing interface layout and interaction logic for Android 13 system features to enhance user experience on that system.

(3) Necessary Communications

• Service Update Notifications: Send major service update notifications via email, such as feature deprecation, data migration, and other important information, ensuring you are timely informed of service changes to make corresponding adjustments.
• Security Alerts: When abnormal login or other security risks are detected in your account, promptly send account security alerts to protect your account security and personal information security.

(4) Compliance Requirements

We fulfill record retention obligations in accordance with laws and regulations. For example, saving transaction information for paid services to meet tax, audit, and other compliance review requirements, while also providing a basis for protecting your transaction rights.

4 Information Sharing and Disclosure

(1) Third-Party Service Providers

We only share your necessary information with third-party service providers when necessary, and sign strict confidentiality agreements with third parties before sharing to ensure your information security.

Cloud Service Providers: We cooperate with renowned cloud service providers (such as AWS, Google Cloud) to store your account data and divination records on their secure and reliable servers. These cloud service providers have industry-leading security standards and use multiple encryption, access control, and other technical measures to ensure data security and integrity.

Payment Processors: If you use paid services, we share necessary information such as order amount and account email with professional payment processors (such as Stripe, PayPal) to smoothly complete the transaction process. We never transmit sensitive information such as your divination content to payment processors.

Data Analytics Service Providers: To better understand user behavior and optimize service functions, we may share anonymized usage data with data analytics service providers (such as Firebase). This anonymized data cannot identify your personal identity.

(2) Legal and Security Requirements

Legal Disclosure Requirements: When receiving legitimate requests from government agencies or judicial authorities (such as subpoenas, court orders), we will disclose necessary information according to law to cooperate with legal proceedings. During this process, we will strictly review the legality and necessity of relevant requests to ensure only information within the scope required by law is disclosed.

Rights Protection Disclosure: When necessary to protect your or others' legitimate rights and interests, such as preventing fraud or responding to emergency security incidents, we may disclose relevant information within a reasonable and necessary scope.

(3) Prohibition of Data Sale

We solemnly promise never to sell any of your personal information, including but not limited to identifiers, divination content, device information, etc. This commitment strictly complies with the explicit requirements for "no data sale" in regulations such as CCPA. We are committed to maintaining your control and privacy rights over personal information.

5 Data Security and Storage

(1) Security Measures

• Encryption Technology Application: During data transmission, we use SSL encryption technology to ensure data security during network transmission and prevent data theft or tampering. For stored data, such as your divination records and other sensitive information, we use AES encryption algorithms for encrypted storage.
• Permission Management and Auditing: We have established a strict internal personnel access permission system, only authorizing specific technical team members to access your data when necessary for troubleshooting, function maintenance, and other necessary work needs. Additionally, we maintain detailed logs of all operations involving data access for subsequent auditing and tracking.
• Security Monitoring and Maintenance: We regularly conduct comprehensive security audits and vulnerability scanning to timely discover and fix potential data security vulnerabilities. We also continuously monitor the latest security threats and protection technologies in the industry, constantly updating and improving our security protection system.

(2) Data Retention Period

Account Information: We will retain your account information during the existence of your account. If you apply for account cancellation, after completing the relevant cancellation process, we will delete your account information according to relevant laws and regulations to ensure your personal information is no longer retained.

Device and Usage Data: For device and usage data, after anonymization processing, we may retain it long-term for continuous service optimization work. Data after anonymization processing can no longer be associated with your personal identity.

(3) Cross-Border Data Transfer

If cross-border data transfer is necessary for business needs, we will strictly follow relevant legal and regulatory requirements, ensuring data security and compliance during cross-border transfer through compliant methods such as signing standard contracts, protecting your personal information rights from harm.

6 Your Rights

According to rights granted to you by regulations such as GDPR and CCPA, you enjoy the following rights in our Services:

(1) Correction and Deletion

• Information Correction: If you find errors in your account information, you can directly modify it in the APP settings, conveniently and quickly updating your personal information to ensure information accuracy.
• Record Deletion: If you need to delete all divination records, you can contact our customer service team at any time (provided at the end of this document). We will promptly delete relevant records according to your requirements after verifying your identity.

(2) Account Cancellation

You can conveniently apply for account cancellation in the APP's "Settings - Account Security." After you submit a cancellation application, we will process all your data according to the data retention period provisions in Section 5.2 of this Policy, and account cancellation is irreversible.

(3) Obtaining Information Copy

If you need to obtain a copy of your personal information in our Services, you can contact our customer service. We will provide you with a copy of your personal information in a secure and convenient manner after verifying your identity.

(4) Withdrawing Consent

You have the right to withdraw your consent authorization for our collection and use of your personal information at any time. You can withdraw your consent through relevant settings in the APP or by contacting customer service. However, please note that withdrawing consent may affect your continued use of some service functions that depend on that authorization.

(5) Account Security

When the platform discovers user data and privacy breaches (only under high-risk conditions), we will notify users within 72 hours (contacting users through the method provided at the end of this document) and report to relevant authorities.

7 Children's Protection

This Service is explicitly not intended for minors under 13 years old. We will comply with COPPA and GDPR. Users must confirm they meet age requirements during registration, and we will also display applicable age markers in app stores. If we discover during operation that a user is a minor, we will immediately stop collecting their personal information and delete the stored minor's data according to relevant laws and regulations (unless law requires retention of certain information).

If guardians discover minors using this Service without authorization, they can contact our customer service at any time, and we will fully assist in handling the matter to protect minors' personal information security.

8 Policy Updates

(1) Update Notifications

If this Policy changes, we will promptly notify you through APP pop-ups, email (if you have provided an email address), and other methods. For major changes (such as expanding information collection scope, changing information sharing methods, and other changes that may significantly impact your rights), we will obtain your explicit consent before the changes take effect. For non-major changes, we will also promptly notify you so you can understand our latest adjustments to personal information processing methods.

(2) Changes Taking Effect

Policy changes will take effect after a reasonable period from the notification date. If you continue to use our Services after changes take effect, you are deemed to have agreed to the updated Privacy Policy. If you disagree with the changed Policy, you have the right to stop using our Services and exercise your relevant rights under this Policy, such as account cancellation, information deletion, etc.