Privacy Policy

1. Introduction

Beijing Tuyu Culture Co., Ltd. ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at tuyuwenhua.com (the "Site") or use our mobile applications available on Google Play Store and Apple App Store (the "Apps").

Please read this Privacy Policy carefully. By accessing or using our Site and Apps, you acknowledge that you have read, understood, and agree to be bound by all the terms of this Privacy Policy.

2. Information We Collect

2.1 Personal Information

We may collect personal information that you voluntarily provide to us when you:

• Contact us through our website or mobile applications
• Sign up for our services or newsletters
• Participate in cultural exchange programs or events
• Create an account within our mobile applications
• Submit artistic content or creative works

This information may include:

• Name and contact information (email address, phone number, mailing address)
• Demographic information (age, gender, nationality)
• Professional information (company name, job title)
• Payment information (when purchasing products or services)
• User-generated content and artistic submissions

2.2 Automatically Collected Information

When you access our Site or use our Apps, we automatically collect certain information, including:

• Device information (device type, operating system, unique device identifiers)
• Usage data (pages visited, features used, time spent on app)
• Location data (country, region - may be approximate)
• IP address and browser type
• Advertising identifiers (for ad personalization)

3. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our services
• Process transactions and send related information
• Send promotional communications and marketing materials
• Respond to your comments, questions, and requests
• Monitor and analyze usage patterns and trends
• Personalize and improve your experience
• Display targeted advertisements through our advertising partners
• Detect, prevent, and address technical issues or fraud
• Comply with legal obligations

4. Advertising and Third-Party Advertisers

We partner with third-party advertising networks and platforms to display advertisements within our mobile applications. These partners help us generate revenue to support our services.

4.1 Integrated Advertising Platforms

Our mobile applications integrate with the following advertising platforms:

4.2 Types of Advertisements

Our applications may display the following types of advertisements:

• Splash Ads (开屏广告): Full-screen advertisements displayed when the app launches
• Rewarded Video Ads (激励视频广告): Video ads that users can watch to earn in-app rewards
• Interstitial Ads (插屏广告): Full-screen ads displayed during natural transitions
• Banner Ads (Banner广告): Rectangular ads displayed at top or bottom of screen
• Native Ads (原生广告): Ads designed to match app content appearance
• Offer Wall (优惠墙): Walls of sponsored offers for user engagement

4.3 How Advertising Works

Our advertising partners collect and use information about your device and app usage to display relevant advertisements. This may include:

• Device identifiers (Android Advertising ID, IDFA)
• App usage and browsing behavior
• Location information (with your consent)
• Age and gender (if provided)
• Interest-based data for ad targeting

You can opt out of personalized advertising by adjusting your device settings or app preferences.

5. International Privacy Compliance

5.1 GDPR (European Union)

If you are located in the European Economic Area (EEA), we process your personal data in accordance with the General Data Protection Regulation (GDPR). You have the right to:

• Access your personal data
• Rectify inaccurate personal data
• Request erasure of your personal data ("right to be forgotten")
• Restrict processing of your personal data
• Data portability
• Object to processing
• Withdraw consent at any time

5.2 CCPA (California, USA)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information is collected
• Right to know how personal information is used and shared
• Right to delete personal information
• Right to opt-out of sale of personal information
• Right to non-discrimination for exercising your rights

5.3 PIPEDA (Canada)

We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) for users in Canada, ensuring appropriate consent and data protection measures.

5.4 LGPD (Brazil)

For users in Brazil, we process personal data in accordance with the Lei Geral de Proteção de Dados (LGPD), respecting privacy rights and data protection principles.

5.5 PDPA (Singapore & Thailand)

We comply with the Personal Data Protection Act in Singapore and Thailand, ensuring lawful processing and protection of personal data.

6. Children's Privacy (COPPA & GDPR-K)

Our services are not directed to children under the age of 13 (or 16 in certain jurisdictions). We do not knowingly collect personal information from children under these ages.

6.1 COPPA Compliance (USA)

In compliance with the Children's Online Privacy Protection Act (COPPA), we do not collect personal information from children under 13 without verifiable parental consent. If we become aware that we have collected data from a child under 13 without parental consent, we will take steps to delete that information promptly.

6.2 GDPR-K Compliance (Europe)

For users in the European Union under 16 years of age (or the applicable age of consent in your country), we require parental consent before processing personal data. We implement age verification measures and parental consent mechanisms as required by GDPR-K.

6.3 Other Jurisdictions

We comply with applicable children's privacy laws in all jurisdictions where we operate, including but not limited to the Australian Privacy Principles regarding children's data.

7. App Store Policies Compliance

7.1 Google Play Store

Our Android applications comply with Google Play Store policies, including:

• Privacy Policy requirements
• Data safety disclosure requirements
• Advertisements policy compliance
• Family Ads Program requirements (if applicable)
• Targeted Ads policy
• Device and network abuse policies

7.2 Apple App Store

Our iOS applications comply with Apple App Store Review Guidelines, including:

• Privacy requirements
• App Tracking Transparency (ATT) framework
• Advertising identifiers guidelines
• Data collection and storage requirements
• Kids category requirements (if applicable)

8. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Regular security assessments and testing
• Access controls and authentication measures
• Secure data storage practices
• Employee training on data protection
• Incident response procedures

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

9. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law. The criteria we use to determine retention periods include:

• The nature and sensitivity of the information
• The purposes for which we process it
• Applicable legal and regulatory requirements
• Our legitimate business interests
• Whether deletion would impede legal claims or investigations

10. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information:

• Access: Request copies of your personal data
• Rectification: Request correction of inaccurate data
• Erasure: Request deletion of your data
• Restriction: Request limitation of data processing
• Portability: Request transfer of your data
• Objection: Object to processing of your data
• Withdraw Consent: Withdraw previously given consent
• Lodge Complaint: File a complaint with data protection authorities

To exercise these rights, please contact us at privacy@tuyuwenhua.com.

11. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws. When we transfer personal data internationally, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs)
• Binding Corporate Rules
• Privacy Shield certifications (where applicable)
• Other legally approved transfer mechanisms

12. Cookies and Similar Technologies

We use cookies and similar tracking technologies to collect and track information about your browsing activities. These include:

• Essential cookies (required for service functionality)
• Analytics cookies (to understand usage patterns)
• Advertising cookies (for ad personalization)
• Third-party cookies (from our advertising partners)

You can control cookies through your browser settings or device preferences.

13. Third-Party Services

Our Site and Apps may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.

14. Changes to This Privacy Policy

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

• Posting the updated policy on our Site
• Updating the "Last Updated" date at the top of this policy
• Sending email notification (for significant changes)
• Providing in-app notifications (for App updates)

Your continued use of our Site and Apps after any changes indicates your acceptance of the updated Privacy Policy.

15. Contact Us

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

Last Updated: January 15, 2025