Privacy Policy

We take your privacy with the utmost seriousness, and this privacy statement explains how Xunya International Limited (collectively, "we," "us," or "our") collects, uses, shares, and processes your personal information.

Collection and Use of Personal Data

Personal data refers to information that can directly or indirectly identify you. It also includes anonymous data linked to information that can be used for direct or indirect identification of you. Personal data does not cover irreversibly anonymized or aggregated data that no longer enables us to identify you, whether in combination with other information or by any other means.

Promoting Safety and Security

We adhere to the principles of legality, legitimacy, and transparency, processing and using the minimum necessary data for specified and limited purposes. We also adopt technical and administrative measures to protect data security. We use personal data to verify accounts and user activities, as well as to enhance safety and security — for example, by monitoring fraud and investigating suspicious, potentially illegal activities, or violations of our terms and policies. Such processing is based on our legitimate interest in ensuring the safety of our products and services.

Below is a detailed description of the types of personal data we may collect and the ways we may use them:

What Personal Data We Collect

ⅰ. Data you voluntarily provide:

We collect the personal data you submit when using our products and services or interacting with us in other ways, such as creating an account, contacting our customer service, participating in online surveys, or using our online help and chat tools. If you make a purchase, we will collect personal data related to the transaction, including your payment details (such as credit or debit card number and other card information), account and authentication data, as well as billing, shipping, and contact information.

ⅱ. Data about your use of our services and products:

When you visit our websites, we may collect data such as your device type, unique device identifier, device IP address, operating system, Internet browser type, usage statistics, diagnostic information, and location data from the computers, phones, or other devices on which you install or access our products and services. Where available, our services may use GPS, your IP address, and other technologies to determine your device's approximate location, so as to continuously improve our products and services.

How We Use Your Personal Data

In general, we use personal data to provide, enhance, and develop our products and services, communicate with you effectively, offer targeted advertisements and personalized services, and protect the legitimate rights and interests of us and our customers.

ⅰ. Providing, improving, and developing our products and services:

We use personal data to support the provision, improvement, and development of our products, services, and advertising campaigns, including for data analysis, market research, and internal audits. Such processing is based on our legitimate interest in providing you with quality products and services and ensuring business continuity. If you participate in a contest or other promotional activities, we may use the personal data you provide to administer these programs. Some of these activities have separate additional rules that may include more details on our data use practices, so we recommend you read these rules carefully before participating.

ⅱ. Communicating with you:

With your prior express consent, we may use your personal data to send you marketing communications about our own products and services, contact you regarding your account or transactions, and notify you of updates to our policies and terms. If you no longer wish to receive marketing emails, you may contact us to unsubscribe at any time. We also use your data to process and respond to your inquiries and requests when you contact us. With your prior express consent, we may share your personal data with our third-party partners for them to send you marketing communications about their own products and services. With your prior express consent, we may also use personal data to personalize your experience with our products and services (as well as on third-party websites and applications) and to measure the effectiveness of our promotional campaigns.

NOTE: For any of the above data uses that require your prior express consent, you have the right to withdraw your consent at any time by contacting us.

Definition of Cookies

Cookies are small text files used to store information on web browsers. They are widely used to store and retrieve identifiers and other information on computers, phones, and other devices. We also use other similar technologies (including data stored on your web browser or device, device-associated identifiers, and other software) for the same purposes. In this Cookie Statement, all such technologies are collectively referred to as cookies.

Use of Cookies

We use cookies to provide, protect, and improve our products and services — for example, by personalizing content, offering and measuring the effectiveness of advertisements, understanding user behavior, and providing a safer browsing and shopping experience. Please note that the specific cookies we use may vary according to the particular websites and services you access.

Disclosure of Personal Data

We may share certain personal data with strategic partners who cooperate with us to provide our products and services or assist us with customer marketing. We only share personal data with these companies to provide or improve our products, services, and advertising; we will not share your personal data with third parties for their own marketing purposes without your prior express consent.

Data Disclosure, Storage, Transfer, and Processing

ⅰ. Fulfilment of legal obligations:

Pursuant to the mandatory laws of the European Economic Area (EEA) or the country/region where you reside, we may need to process your personal data to comply with existing legal acts and fulfill relevant legal obligations. Processing of personal data of EEA residents — As outlined below, if you are a resident of the EEA, our processing of your personal data shall be lawful: Where we require your consent for the processing of your personal data, such processing shall be justified in accordance with Article 6(1) of the General Data Protection Regulation (EU) (GDPR).

ⅱ. For the proper implementation and application of this statement:

We may share personal data with all of our affiliated companies. In the event of a merger, reorganization, acquisition, joint venture, assignment, spin-off, transfer, sale, or disposition of all or any part of our business (including in connection with bankruptcy or similar legal proceedings), we may transfer all of your personal data to the relevant third party. We may also disclose your personal data if we reasonably determine that such disclosure is necessary to protect our legal rights, pursue available legal remedies, enforce our terms and conditions, investigate fraud, or safeguard our normal operations and the rights of our users.

ⅲ. Legal Compliance, Security, and Protecting Other Rights

We may be required to disclose personal data by law, legal process, litigation, or requests from public and governmental authorities (whether within or outside your country of residence). We may also disclose personal data if we determine that such disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance.

Children

Our products and services are intended for adult users only. Therefore, we do not knowingly collect, use, or disclose personal data from children under the age of 16. If we learn that we have inadvertently collected personal data from a child under 16 (or the equivalent minimum age as required by local jurisdiction laws), we will take immediate steps to delete such data from our systems. Please contact us immediately if you become aware that a child under 16 has provided us with personal data.

Your Rights

We take reasonable measures to ensure that your personal data is accurate, complete, and up-to-date. You have the right to access, correct, or delete the personal data we collect about you. You also have the right to restrict or object to the further processing of your personal data at any time, and to receive your personal data in a structured, commonly used, and machine-readable format. You may lodge a complaint with the competent data protection authority regarding our processing of your personal data. To protect the privacy and security of your personal data, we may request relevant information from you to verify your identity and your right to access the requested data, as well as to search for and provide the personal data we maintain. In some cases, applicable laws or regulatory requirements may allow or require us to refuse to provide or delete some or all of the personal data we hold. You may contact us to exercise your above-mentioned rights, and we will respond to your request within a reasonable time frame (and in any case, within 30 days).

Third-Party Websites and Services

When you click on a link to a third-party website that has a cooperative relationship with us, we assume no liability or responsibility for the third party's privacy policy. Our websites, products, and services may contain links to, or provide access to, third-party websites, products, and services. We are not responsible for the privacy practices of these third parties, nor for the information or content contained in their products and services. This Privacy Statement applies solely to the data we collect through our own products and services. We encourage you to read the privacy policies of any third party before using their websites, products, or services.

Data Security, Integrity, and Retention

We adopt reasonable technical, administrative, and physical security measures to protect your data from unauthorized access and ensure the proper use of the data we collect. We will retain your personal data only for as long as it is necessary to fulfill the purposes outlined in this Privacy Statement, unless a longer retention period is required or permitted by applicable law.

Changes to this Privacy Statement

We may revise this Privacy Statement from time to time to adapt to new technologies, industry practices, regulatory requirements, and other relevant factors. Your continued use of our products and services after the effective date of the revised Privacy Statement constitutes your acceptance of the changes. If you do not agree to the revised Privacy Statement, please cease using our products and services and contact us to close any account you may have created.

Minors’ Privacy

We are committed to protecting the privacy of individuals under the age of 18. We do not knowingly collect, use, or disclose personal information from anyone under the age of 18. If we become aware that we have inadvertently collected personal data from a minor, we will take reasonable and prompt steps to delete such information from our records. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us immediately so that we can address the matter in a timely manner.