Privacy Agreement

1. Data Controller and Scope

This Privacy Agreement applies to the website and mobile applications operated by Henan Lingtuo Information Technology Co., Ltd, including products distributed through Google Play, Apple App Store, and other legally available application marketplaces. It governs personal data handling related to AI consulting services, IoT applications, engineering services, intelligent equipment services, advisory services, supply chain services, and digital transformation technical services.

Company: Henan Lingtuo Information Technology Co., Ltd

Office Address: No. 1-A118, Building 1, Second Village Collective Economic Industrial Park, Emperor Temple Township, Linying County, Luohe, Henan, 462000, China

Website: https://hnLingtuo.com

Business Support: support@hnLingtuo.com

Key Accounts: dingyi1@hnlingtuo.com

2. Categories of Information We Process

• Identity and account information: name, email, organization, role identifiers, account IDs, and hashed credentials.
• Contact and support information: support requests, business inquiry details, communication history, and issue tracking records.
• Device and technical information: device model, operating system, language, app version, crash traces, network type, timezone, and diagnostic logs.
• Usage and interaction information: feature usage, session events, in-app navigation, transaction and operation records, and event timestamps.
• Location and network information: approximate location inferred from IP, network carrier, and connectivity state when required for service operation.
• Security and fraud data: login anomalies, anti-abuse signals, risk scoring metadata, and audit records.
• Advertising and monetization data: advertising identifiers (such as AAID/IDFA where permitted), ad impression records, ad interaction events, and consent signals.
• Business integration data: data imported from enterprise systems under customer instruction, processed according to signed service arrangements.

3. Purposes and Legal Bases

• Service delivery and account operations, based on contract performance and legitimate interests.
• Technical support, quality assurance, and reliability improvements, based on legitimate interests.
• Security controls, fraud prevention, and compliance reporting, based on legal obligations and legitimate interests.
• Analytics and product optimization, based on consent where required and legitimate interests where permitted.
• Advertising monetization and personalized advertising in app contexts, based on consent in applicable jurisdictions and user controls provided by platform settings.
• Regulatory response and legal claims management, based on legal obligations and legitimate interests.

4. App Marketplace and Platform Compliance

For applications listed in Google Play, Apple App Store, and other marketplaces, we align data handling with platform disclosure requirements, privacy nutrition labels, data safety forms, and policy review processes. We document:

• Data collected by the app and SDK providers.
• Data sharing, transfers, and retention periods.
• Purpose mapping for functionality, analytics, fraud prevention, and advertising.
• Account deletion mechanisms where applicable.
• User rights request channels and response timelines.

5. Advertising, Ad SDK, and Monetization Compliance

Our mobile applications may integrate advertising and mediation technologies, including but not limited to Google AdMob, Google Ad Manager, AppLovin MAX, Unity Ads, ironSource, Meta Audience Network, Pangle, Mintegral, Vungle/Liftoff Monetize, Chartboost, InMobi, Start.io, Moloco, and equivalent approved providers for lawful monetization.

Supported ad formats may include:

• Splash or App Open ads.
• Rewarded video ads.
• Interstitial ads.
• Banner ads.
• Native ads.

Where required by law or platform policy, consent management is implemented for ad personalization, measurement, and ad storage/read access. We support restricted processing modes, non-personalized ads, and region-based ad behavior where mandated.

6. Country and Regional Privacy Law Alignment

We maintain controls designed to align with major privacy frameworks applicable to users and customers, including:

• European Economic Area and European Union: GDPR and ePrivacy requirements.
• United Kingdom: UK GDPR and Data Protection Act standards.
• United States: CCPA/CPRA and applicable state privacy laws, including rights to know, delete, and correct where applicable.
• Canada: PIPEDA and applicable provincial privacy obligations.
• Brazil: LGPD requirements for transparency, legal basis, and data subject rights.
• Japan: APPI requirements for disclosure and transfer governance.
• South Korea: PIPA principles for consent, purpose limitation, and security controls.
• Singapore: PDPA obligations on notification, consent, and protection.
• Australia: Privacy Act and APP obligations on transparency and rights handling.
• India and other jurisdictions: applicable data protection and consumer protection requirements as enacted.

For cross-border transfers, we implement contractual and operational safeguards suitable for the relevant transfer regime.

6A. Policy Adaptation Matrix: Marketplace, Country Policy, Age, and Advertising

• Google Play: Data safety disclosure, SDK declaration, account deletion where applicable, age rating compliance, ad ID controls, and policy-based handling for personalized/non-personalized advertising.
• Apple App Store: App Privacy details, tracking disclosure and permission workflow where required, age rating metadata, and monetization disclosure for ad-supported features.
• European Union and EEA: GDPR legal basis, transparency obligations, rights handling, consent signal management for ad personalization, and transfer safeguards.
• United Kingdom: UK GDPR-based rights and data governance, including withdrawal and objection workflows where applicable.
• United States (state-level): Consumer rights routing (know, delete, correct, limit where applicable), disclosure obligations, and opt-out handling for sharing as defined by local law.
• Canada: Notice and accountability obligations under PIPEDA-style principles and local provincial requirements where applicable.
• Brazil: LGPD legal basis controls, rights management, and transfer protection obligations.
• Japan, South Korea, Singapore, Australia, and other jurisdictions: localized notice, purpose limitation, and rights handling according to applicable law.
• Age and child policy adaptation: audience configuration, child-directed controls where required, parental-consent pathways, and ad-limitation modes for child or mixed audiences.
• Advertising formats governance: app open/splash ads, rewarded video, interstitial, banner, and native placements are configured with region, age, and consent constraints.

7. Children, Teen Users, and Age Controls

Our enterprise-oriented services are generally not directed to children. For mobile applications, we apply age labeling and audience configuration consistent with app store rules. Where required, we implement child-directed treatment, limited ad behavior, and parental-consent workflows. We do not knowingly process personal data from children in violation of applicable law.

For age-related requests, contact support@hnLingtuo.com.

8. Data Sharing and Third Parties

• Infrastructure and hosting providers for secure service operation.
• Analytics, crash reporting, and performance monitoring processors.
• Advertising and monetization partners, as configured by app functionality and consent status.
• Authorized service partners and subcontractors under contractual confidentiality and security obligations.
• Regulators, courts, and law enforcement where legally required.

We do not sell personal data in a manner inconsistent with applicable law. Where "sale" or "sharing" definitions apply under local law, we provide rights handling mechanisms as required.

9. Data Retention and Deletion

We retain personal data only as long as necessary for service delivery, contractual obligations, legal compliance, and dispute resolution. Retention periods vary by record type, jurisdiction, and operational need. Deletion and anonymization routines are executed according to internal control schedules and customer agreements.

10. Security Measures

• Access control with role-based restrictions and authentication safeguards.
• Data transmission protection and environment isolation controls.
• Monitoring, logging, and anomaly detection for abuse and security threats.
• Vulnerability management and patch governance processes.
• Incident response and escalation workflows for security events.

No system can be guaranteed as absolutely secure, but we continuously improve protections based on risk evaluation and industry practice.

11. User Rights and Requests

Depending on jurisdiction, users may have rights to access, correct, delete, restrict processing, object, portability, and withdraw consent. Users may also request information regarding categories of personal data, processing purpose, and third-party disclosures where required by law.

Requests can be submitted to support@hnLingtuo.com. We may verify identity before processing requests and will respond within legally required timeframes.

11A. Data Subject Request Workflow

• Request Intake: receive request through official support channels and register request type.
• Identity and Authority Verification: validate identity or legal authorization before disclosure or deletion action.
• Scope Determination: identify systems, records, and processors involved in the request.
• Response Execution: provide requested action or lawful explanation within applicable legal timelines.
• Recordkeeping: retain a compliance record of request handling and final outcome.

12. Cookies, SDKs, and Similar Technologies

Our website and apps may use cookies, local storage, SDK identifiers, and similar technologies for authentication, reliability, analytics, and monetization. Consent and preference controls are presented where required by law or platform policy.

12A. Consent Management and Preference Controls

• Region-aware consent prompts are displayed when required by law or marketplace policy.
• Users can update privacy and ad-preference settings where supported by product design and platform controls.
• Consent state may determine whether personalized advertising, certain analytics, or identifier access is enabled.
• For child or age-restricted contexts, monetization and tracking behavior may be reduced or disabled.

13. Policy Updates

We may update this Privacy Agreement to reflect legal, technical, product, or operational changes. Material changes will be communicated through website posting, in-app notice, or equivalent channels as required.

14. Contact for Privacy Matters

Email: support@hnLingtuo.com

Key Account Contact: dingyi1@hnlingtuo.com

Address: No. 1-A118, Building 1, Second Village Collective Economic Industrial Park, Emperor Temple Township, Linying County, Luohe, Henan, 462000, China