Privacy Policy

This policy covers the 衍象坊 website, mobile pages and related services. In relation to your personal information we act as a "personal information handler" under Mainland Chinese law, a "data user" under Hong Kong law, an "organisation" under Singapore law, and a "business" or "controller" under US state privacy laws.

Third parties integrated into the Service — payment providers, identity providers, advertising and analytics vendors — are responsible for their own independent processing under their own policies, which this policy does not cover.

If you do not agree with this policy, please stop using the Service. Some features cannot be provided without the necessary information.

We collect only what is necessary. Unless the law provides otherwise, declining to provide optional information does not prevent you from using core features.

• Account information: Nickname, avatar, email address, the identifier and basic profile returned by third-party sign-in (Auth0, Casdoor, Google), and password credentials stored in encrypted form.
• Service inputs: The characters and questions you enter, date and time of birth, place of birth or coordinates, chart parameters, AI conversations and follow-up questions, bookmarks and history.
• Images: Facial photographs you upload to the AI face-reading feature, and the facial-feature descriptions the model derives from them.
• User content: Text and images you post in the square, wish wall, gratitude wall, comments and private messages.
• Transactions and subscriptions: Order numbers, payment status, membership tier and period, credit ledger entries, and the recipient name, phone number and address for merchandise. Full card numbers are handled by Stripe; we neither receive nor store them.
• Device and log data: IP address, device model, operating system, browser type and version, language and time zone, referring page, access times and page views, error and performance logs.
• Cookies and local storage: Used to keep you signed in, remember language and preferences, prevent abuse, and for analytics and advertising (see section 5).
• Location: Only where you grant permission or enter it yourself, for coordinate-based calculations such as true solar time and sky maps. We may also infer a coarse, city-level location from your IP address for security and content adaptation.

The following count as sensitive personal information under China's Personal Information Protection Law, and as biometric information under laws such as the Illinois Biometric Information Privacy Act (BIPA) and Texas CUBI: date and place of birth, facial photographs and the facial-feature information derived from them, and any health, religious or relationship details you volunteer in free text.

We process such information only after separately informing you of the purpose, method and necessity and obtaining your separate consent, and strictly only as far as the relevant feature requires. Specifically, for facial photographs:

• The photograph is used to generate that face-reading interpretation and is kept as part of your session record so you can revisit it and ask follow-up questions;
• It is stored in Cloudflare R2 object storage and served over a random, unguessable link — please do not share that link with others;
• During analysis the photograph is transmitted to our AI model provider (Anthropic) for image understanding; the temporary working directory on our server is deleted as soon as the analysis ends;
• We do not use facial photographs for identification or matching, do not build a facial-feature database, do not use them to train our own models, and do not sell them or use them for ad targeting;
• You can delete a session from your face-reading history at any time, which removes both the database record and the stored photograph.

You may withdraw consent to the processing of sensitive personal information at any time. Withdrawal does not affect processing already carried out on the basis of that consent; afterwards we stop the relevant processing and delete or anonymise the information as described in this policy. We do not use metaphysics-related information to infer your health, disease risk or creditworthiness, and we do not use it to make automated decisions with a significant effect on your rights.

• Core functionality: Performing chart calculations and inference, generating AI interpretations, saving history, and maintaining sign-in and sessions.
• Transactions: Settling credits and subscriptions, issuing receipts, fulfilment and after-sales support, and preventing payment fraud.
• Security: Detecting unusual sign-ins, abuse and attacks, enforcing rate limits and risk controls, and troubleshooting.
• Improvement: Analysing feature usage in aggregate to improve the interface, algorithms and content quality.
• Communication: Sending service-related notices such as renewal, billing and security alerts; with your consent, product and event updates, from which you can unsubscribe at any time.
• Advertising: Displaying advertising through Google AdSense to support the platform (see section 5).
• Legal obligations: Responding to regulatory requirements and lawful requests from judicial authorities.

Legal bases: in Mainland China we rely mainly on your consent, necessity for entering into or performing a contract, compliance with statutory duties, and the reasonable processing of information you have made public. In Hong Kong we follow the Data Protection Principles on collection purpose and use limitation. In Singapore we rely on consent, deemed consent or a statutory exception. In the United States we rely on the notice-and-choice mechanisms of the applicable state laws. If we ever need to use your information for a purpose not described here, we will tell you and obtain consent again.

• Essential cookies: Keep you signed in and your session secure, remember language and theme preferences, and guard against cross-site request forgery and abuse. These cannot be turned off.
• Experience analytics: We use Microsoft Clarity to understand how pages are used. It may record page views, clicks, scrolling and session replays, masking input fields according to its default settings. Microsoft processes that data under its own privacy statement.
• Advertising: We use Google AdSense. Google and its partners may use cookies and advertising identifiers to serve personalised ads — which under California law may count as "sharing" personal information for cross-context behavioural advertising. You can turn personalised advertising off in Google's Ad Settings, or contact us using the details below and we will action your opt-out.
• Managing cookies: You can clear or block cookies in your browser. We are building in-product cookie and advertising preference controls and working towards support for the Global Privacy Control (GPC) signal; until then, contact us using the details below and we will process your opt-out manually. Disabling some cookies may affect sign-in and preference storage.

We do not sell your personal information. We share it or engage processors only in the following cases:

• With your express consent or on your instruction;
• With service providers necessary to deliver the Service: Auth0, Casdoor and Google (authentication and sign-in); Stripe (payments and subscription management); Cloudflare (content delivery, security and R2 object storage); Anthropic and model-gateway providers (AI inference); Microsoft Clarity (experience analytics); Google AdSense (advertising); and email and push-notification providers;
• We sign data-processing terms with these processors requiring them to act on our instructions, apply appropriate security measures, and refrain from any other use;
• Where disclosure is lawfully required by legislation, a regulator or a judicial authority;
• Where necessary to protect the rights, safety or property of the platform, our users or the public;
• In a merger, acquisition, reorganisation or insolvency, in which case we will tell you who the recipient is and require them to remain bound by this policy.

We do not use your service inputs to train our own AI models without your separate consent. How third-party model providers use data is governed by our agreements with them and their own policies; we prefer providers that commit not to train on API data.

Our application servers and database are located in the United States, uploaded files are stored in Cloudflare R2 (globally distributed), and AI inference, payment, authentication and analytics services are provided from the United States and other countries. Your personal information is therefore transferred outside your own country or region.

• Mainland China: Under Articles 38 and 39 of the Personal Information Protection Law we separately inform you of the overseas recipients' names and contact details, the purpose and method of processing, and the categories of personal information involved, and obtain your separate consent. We use the Standard Contract for outbound transfers and comparable safeguards so that overseas processing meets the standard required by Chinese law.
• Hong Kong SAR: We bind overseas recipients contractually, following the Personal Data (Privacy) Ordinance and the Privacy Commissioner's guidance on cross-border transfers.
• Singapore: Under the transfer-limitation obligation of the Personal Data Protection Act we ensure overseas recipients provide a standard of protection comparable to Singapore law.
• United States: Your data is processed and stored primarily within the United States.

If you have questions about cross-border transfers or would like details of the safeguards we use, contact us using the details below.

• Retention: Account information is kept while the account exists. Chart and conversation records and face-reading sessions are kept until you delete them, or removed within 30 days of account closure. Transaction and accounting records are kept for at least three years from completion, as required by China's E-Commerce Law and comparable rules. Logs are generally kept for 6 to 12 months. Longer statutory periods prevail where they apply.
• Security measures: HTTPS across the site; passwords stored using irreversible hashing; access control and least privilege for the database and object storage; audit trails for critical operations; regular security updates and backups.
• Residual risk: Despite these measures, no internet service is absolutely secure. Keep your credentials safe and avoid staying signed in on shared devices.
• Breach notification: If personal information is or may have been leaked, altered or lost, we activate our incident response immediately and notify you and the authorities as required: in Mainland China under Article 57 of the Personal Information Protection Law; in Hong Kong following the Privacy Commissioner's recommended notification; in Singapore, under the mandatory regime, notifying the PDPC no later than 3 calendar days after assessment; and in the United States within the deadlines set by applicable state breach-notification laws.

Wherever you are, you can exercise the following rights through your account settings or by contacting us:

• Know and access: Find out what personal information we process about you and obtain a copy.
• Correct and complete: Rectify inaccurate or incomplete information.
• Delete: Request deletion where the law provides, or delete history, face-reading sessions and published content yourself.
• Withdraw consent: Withdraw consent previously given, including separate consent for sensitive personal information.
• Close your account: Request closure at any time; we then handle your data as described in this policy.
• Portability: Where technically feasible, have your personal information transferred to another handler you designate.
• Explanation: Ask us to explain how we process personal information.
• Restrict or object: Opt out of targeted recommendations and personalised advertising, and restrict specific processing.

How to exercise these rights: send your request using the contact details below. We may verify your identity to protect your account. Response times: 15 working days in Mainland China, 40 days in Hong Kong, 30 days in Singapore (extendable with notice), and 45 days in the United States (extendable by a further 45 days with notice). Except where the law allows, exercising your rights is free of charge.

• The Service is intended for adults. Users under 18 should use it with the consent and supervision of a parent or guardian;
• We do not offer the Service to children under 13 and do not knowingly collect their personal information (COPPA);
• In Mainland China we obtain the separate consent of a parent or guardian before processing the personal information of minors under 14, and maintain dedicated processing rules (Article 31 of the Personal Information Protection Law; Provisions on the Online Protection of Children's Personal Information; Regulations on the Protection of Minors in Cyberspace);
• If we find that we have collected a minor's information without the necessary consent, we delete it promptly. Guardians may also contact us to review, correct or delete it.

• We use algorithms for content ranking, recommendation and risk control; this processing does not amount to automated decision-making with a significant effect on your rights;
• Under China's Provisions on the Administration of Algorithmic Recommendation, you may turn off personalised recommendations or choose options not based on your personal characteristics; the in-product switch is still being built, so until then ask us using the details below and we will turn it off for you;
• AI interpretations are generated by models, do not represent our judgement, and are not an assessment of you or professional advice;
• If you believe automated processing has adversely affected you, you may ask us to explain it and to carry out a human review.

• We may update this policy from time to time; updates are published on this page with a version number and effective date;
• For material changes to the purpose, categories or methods of processing, we notify you separately by site announcement, in-product notice or email, and seek fresh consent where required;
• We encourage you to review this policy periodically. Previous versions are available on request.