GDPR Privacy Notice

At XUANZHI INTERNATIONAL CO., LIMITED ("XUANZHI”), we are committed to safeguarding the privacy of personal data. This privacy notice explains how XUANZHI processes your personal data, and your rights in relation to the personal data we hold.

Does this GDPR Privacy Notice apply to me?

  • This GDPR Privacy Notice applies to you if:
  • You are a "Person” or "Data Subject”—meaning a natural person, not a corporation, partnership, or other legal entity—who is physically present in the EEA;
  • It is with respect to your "Personal Information”—meaning any information relating to an identified or identifiable person—that is provided while you are physically present in the EEA;

The types of information we collect:

  • Under the European Union’s General Data Protection Regulation (GDPR), personal data is defined as:
  • "Any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
  • The personal data that XUANZHI collects about you includes:
  • IP address;
  • Device identifiers;
  • Web browser information;
  • App activity such as app installation, app uninstallation;
  • Browser cookies and other technologies such as pixel tags and web beacons;
  • Location information;
  • Log data (e.g. access times, hardware and software information);
  • Device event information such as crashes and system activity;
  • Metadata concerning your Android apps;
  • We are required or authorized by applicable laws to collect and process in order to authenticate or identify you or the information you have provided.

How we process information about you

  • Under the GDPR, processing is defined as:
  • "Any operation of set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization,
  • structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.”
  • We process Personal Data to operate, improve, understand and personalize our services. For example, we use Personal Data to:
  • Create and manage your profiles;
  • Analyze how you use our services;
  • Optimize our website content;
  • Inform you of the scope of services offered;
  • Communicate with you;
  • Deal with any concerns or feedback you may have;
  • Resolve disputes;
  • Prevent and detect crimes;
  • Meet contract or legal obligations
  • For any other purpose for which you provide us with your personal data.

Sharing your personal information

For the purposes referred to in this privacy notice and relying on the bases for processing as set forth above, we may share your personal data with certain third parties. You are given the opportunity to opt-in to some of these data sharing agreements, where XUANZHI does not have a legitimate basis, or contractual purpose for sharing the data. XUANZHI will not share your personal data with third parties unless it is necessary for the legitimate interests of XUANZHI in providing you services, or where it is necessary for the purposes of entering into or carrying out a contract between you and XUANZHI. Where the sharing of data would not be necessary for the legitimate interests of XUANZHI or necessary for contractual purposes, we will obtain your consent before sharing your data with said third parties.

Any third parties that we may share your data with are obliged to keep your details secure, and to use them only to fulfill the service they provide you on our behalf.

Your rights as a data subject

  • At any point while XUANZHI is in possession of, or processing your personal data, you, the data subject, have the following rights:
  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply, you have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organization.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing – you also have the right to be subject to the legal effects of automated processing.
  • Right to judicial review: in the event that XUANZHI refuses your request under any of the above rights, we will provide you with a reason as to why.

Under what circumstances will XUANZHI contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimize the risk of unauthorized access or disclosure. Notwithstanding this, XUANZHI will contact you if we identify that a breach affecting your personal data has occurred.

How to contact us

If you have any questions related to this GDPR Privacy Notice, please contact us via

Changes and amendments to this policy

From time to time, we may update or amend this GDPR Privacy Notice to reflect new or different privacy practices, without notice to you. However, if these changes are material, we will place a notice on our website.