D.Y.B.J. Tech & Culture Ltd. Privacy Policy

Introduction

D.Y.B.J. Tech & Culture Ltd. (“D.Y.B.J.”, “we”, “us”) recognizes that data is an important operational asset of our company. By using our websites, applications, or any form of services (collectively, the “Services”), you agree that we may collect, use, and retain your information in accordance with this Policy. This Policy is available at any time in the app under “Settings / Privacy” and on our website.

1. Data Collection

We may collect information about you as permitted by applicable laws and only as necessary to provide the Services, including but not limited to:

Directly Provided: personal information (name, phone number, address, payment information, identity documents) where required by the service flow; health/sensitive information only when you voluntarily provide it or where processing is lawful.

Interaction Records: customer support, surveys, and where applicable, audio/video records and chat logs.

System-Collected: browsing or usage records, clicks, IP address, device information, OS and version, crash and performance diagnostics, and (when authorized by you) location information.

Inferred Data: statistics or preferences derived from usage behavior (used only within the purposes described in this Policy).

Third-Party Sources: necessary information provided by partners or service providers under lawful authorization (e.g., payments or push notifications).

New Technologies: if a new feature requires new types of data, we will provide notice in advance and, where required, obtain separate consent before launch.

2. Data Usage

Your information may be used for purposes related to providing and operating the Services, including:

Contract Performance: transaction processing, customer support, shipping (where applicable), verification, and abuse prevention.

Legitimate Interests:

Service operation, quality improvement, error and performance diagnostics, security and risk management.

Marketing or notifications (only with your consent), and personalized recommendations.

When you explicitly enable it in Settings: use of de-identified data for AI/machine-learning model training; you may disable this at any time to stop subsequent use.

Further Use:

De-identified, anonymized, or aggregated data may continue to be used provided it does not identify an individual.

Deleting your account does not affect existing de-identified statistics or model parameters; no new personal data originating from you will be added thereafter.

3. Disclosure

We may disclose or share your information in the following circumstances:

Service Providers: logistics, payments, cloud, push notifications, diagnostics, and analytics processors, all bound by contractual and security obligations and prohibited from using data for their own independent purposes.

Affiliates and Partners: processed within the necessary scope for the purposes stated in this Policy and subject to confidentiality and security obligations.

Government & Legal: where required by law or lawful process (e.g., a court or competent authority).

Corporate Transactions: in a merger, acquisition, or asset transfer, information may be transferred within a reasonable scope with notice where appropriate.

4. Advertising & Analytics

We and third parties (e.g., push or analytics services) may use cookies, pixels, or device identifiers to deliver the Services and measure performance.

If cross-app/website tracking is needed to provide personalized advertising, we will first seek your permission via Apple’s App Tracking Transparency (ATT). If you do not consent, such tracking will not occur. You may withdraw consent at any time in iOS settings or within the app.

5. Cross-Border Transfers

Your information may be processed and stored outside your place of residence. We will take appropriate safeguards (e.g., Standard Contractual Clauses) as required by applicable laws to protect your information.

For GDPR users: cross-border transfers will adopt appropriate safeguards; you may exercise rights of access, rectification, erasure, restriction, portability, and objection as provided by law.

For CCPA users: you may exercise rights of access, deletion, and opt-out of certain sharing as provided by law; we do not sell personal information.

6. Retention

Personal Data: retained only for as long as necessary to fulfill the purposes stated in this Policy and to meet legal retention obligations; upon expiry, data will be deleted or preserved in de-identified form.

Data Kept to Meet Legal Obligations: retained for the statutory periods applicable.

Anonymized/Aggregated/Derived Data: may be retained and used long-term provided it cannot identify an individual.

7. Your Rights & Exceptions

You may have the right under applicable laws to request access, deletion, rectification, or restriction of processing; we will handle such requests in line with applicable law and the purposes of this Policy.

The Services provide an in-app “Delete Account & Data” process that does not require email or phone. After completion, personal data associated with your account will be removed within a reasonable period (except where retention is legally required).

De-identified, anonymized, or aggregated data and existing model parameters will not be used to re-identify an individual and may continue to be retained and used in compliance with law.

If you subscribed via Apple in-app purchases, subscriptions are tied to your Apple account. Deleting your account does not affect subscription status; manage it in iOS: “Settings > Apple ID > Subscriptions”.

8. Agents & Complaints

Authorized agents must submit formal authorization documents and be verified by us before acting on your behalf.

For repetitive or manifestly unfounded requests, we may lawfully refuse or charge a reasonable fee.

For questions or complaints, you may contact us by email or through competent authorities; we will handle them within a reasonable period.

9. Financial Incentives

If discount, points, or promotional programs are offered, we will provide separate notice of the program details and conditions; participation is optional and you may opt out at any time.

10. Minors

The Services are not directed to children under 13. If we learn that data from a child under 13 was collected without verifiable parental or legal guardian consent, we will take appropriate steps to delete it. Where local laws set a higher age, we will follow those requirements.

11. Policy Updates

D.Y.B.J. may amend this Policy due to service or legal changes; material changes will be announced in the Services or on our website and, where required, we will seek renewed consent. Your continued use of the Services after the effective date signifies your acceptance of the updated Policy.

The data categories and purposes described in this Policy will be kept consistent with the “App Privacy” disclosures in App Store Connect; if discrepancies arise, the actual implementation and updated disclosures will prevail.