Privacy Policy
This Privacy Policy explains how HK ZANVIX CO., LIMITED collects, uses, shares, retains and protects personal information when you visit our website at zhiruntong.com or when you use the mobile management application that we distribute through the Apple App Store and Google Play. It is written to be read, not to be skimmed past, and it is intended to satisfy the disclosure obligations that apply to us as a Hong Kong SAR company operating both a business-to-business and a business-to-consumer digital presence.
Our business scope is: IT development and consultancy, import/export & wholesale of general goods, business advisory and marketing planning. The mobile management application is a first-class business line rather than a side project: it is the tool through which many of our customers run IT development and consultancy engagements, plan import/export & wholesale of general goods activity, and run business advisory and marketing planning workflows. Because the Application and the Website share the same accounts, the same corporate infrastructure and, in some cases, the same advertising partners, we have written a single policy covering both. There is no second, reduced privacy regime hidden inside the App Store or Google Play distribution of the Application.
1. Introduction and Scope
1.1 Who we are
For the purposes of this policy, HK ZANVIX CO., LIMITED ("HK ZANVIX", "we", "us", "our") is the controller of the personal information described here. Our registered office is:
- Company: HK ZANVIX CO., LIMITED
- Office: Room 701 (Unit 127), 7/F, Tower B, New Mandarin Plaza, 14 Science Museum Road, Tsim Sha Tsui East, Hong Kong
- Website: zhiruntong.com
- Business support: support@zhiruntong.com
- Key accounts: qiuwentao@zhiruntong.com
Where the context requires it, we refer to our office as the Hong Kong SAR office. The jurisdiction that governs this policy, and the law that most directly applies to us as a corporate entity, is the law of the Hong Kong SAR.
1.2 What this policy covers
This policy applies to:
- the Website, including every page published at zhiruntong.com and the sub-pages and resources linked from it;
- the mobile management application published by us on the Apple App Store and Google Play (the "Application"), including all versions, updates and platform variants of it;
- accounts you create with us, whether through the Website, the Application, or by corresponding with us directly;
- business contacts, prospective customers, suppliers, distributors and business partners with whom we exchange personal information in the course of IT development and consultancy, import/export & wholesale of general goods, business advisory and marketing planning;
- advertising, measurement and analytics technologies that we or our service providers operate in connection with the Website and the Application.
1.3 What this policy does not cover
This policy does not govern third-party services that we do not control, even where they are linked from the Website or integrated with the Application. That includes, without limitation, the Apple App Store and Google Play storefronts and their own terms and privacy policies, advertising networks and their opt-out pages, social platforms, analytics vendors, payment processors, and any other website or application that we link to. Those providers collect and process data under their own privacy notices and their own legal bases. We identify the advertising providers we work with, and the data they use, in Section 9 of this policy.
1.4 How to navigate this policy
- 2. Information We Collect
- 3. How We Use Information
- 4. Legal Bases for Processing
- 5. Sharing and Processors
- 6. International Transfers
- 7. Retention
- 8. Security
- 9. Advertising and Monetisation
- 10. Advertising Formats and User Controls
- 11. Cookies and Similar Technologies
- 12. Regional Rights
- 13. Children's Privacy
- 14. App Store Compliance
- 15. Do Not Track and Global Privacy Control
- 16. Changes to This Policy
- 17. Contact Us
- 18. Effective Date
1.5 Key terms used in this policy
"Personal information" means information relating to an identified or identifiable individual. "Personal data" has the same meaning where we refer to the EU or UK GDPR. "Processing" means any operation performed on personal information, whether or not by automated means, including collection, storage, analysis, disclosure and deletion. "You" means the individual who accesses the Website, uses the Application, or corresponds with us. Where a company engages our services, "you" also includes that company's named personnel whose personal information we process on the company's behalf.
2. Information We Collect
We limit collection to what is necessary for the purposes described in Section 3. The categories below describe what we may collect across the Website and the Application.
2.1 Account and registration data
When you create an account with us, whether in the Application or through a business relationship that has been converted into an account, we collect the identifiers you provide: your name, business email address, company name, job title, business role, country and region, and, where a business relationship is being established, the invoice and tax details you or your finance team supply. If you enable two-factor authentication, we collect the authentication secret and the associated recovery methods. We do not ask you to submit identity documents to the Website or the Application; where identity verification is required for regulated activity such as export compliance, it is handled as a separate, documented process and is not collected through the Application.
2.2 Device and technical data
We automatically collect information about the device and browser used to reach us, including device model, operating system and version, application version and build number, screen resolution and orientation, CPU architecture, memory pressure, preferred language and locale, time zone, network operator, connection type (cellular, Wi-Fi, ethernet), approximate signal strength, browser and user-agent strings, and crash and diagnostic stacks. On the Application we collect this through our own analytics and through the platform telemetry made available to us. We do not attempt to fingerprint devices using techniques that would be treated as tracking under applicable law.
2.3 Usage and interaction data
We record how you interact with the Website and the Application: pages viewed, pages from which you arrived, referring URLs, search terms used within the Application, features opened, records created or edited, in-app purchases, download and installation events, rewarded-ad opt-ins and completions, feature usage frequency, session duration, and error events together with the surrounding context. Within the Application this includes the business data you choose to enter, such as client and supplier names, product descriptions, stock and inventory records, order references, consultancy project milestones, advertising campaign plans and notes. The content of those business records is your business information and is processed so that the Application can present, aggregate and export it back to you and to the people you authorise.
2.4 Optional location information
The Application can request a coarse or precise location so that it can show you locally relevant supplier information, branch availability, and delivery or logistics status for import/export & wholesale of general goods activity. Location access is entirely optional and is off until you grant it. If you decline, the Application continues to function and we receive no location data from you. Where you grant location access, we collect the coordinates or distance from the device, the accuracy of the reading, and the timestamp of the reading. Continuous background location is never required and is not requested.
Location is an optional feature. You can decline the permission at any time in your device settings without losing access to any core Application feature. We do not sell location data and we do not use it to build advertising profiles.
2.5 Advertising identifiers
Where advertising is served in the Application, advertising networks commonly rely on a device advertising identifier: the Apple Identifier for Advertisers (IDFA) on iOS, and the Google Advertising ID (AAID) on Android. Where you have permitted it, we may receive that identifier together with, for example, an inferred country, device model, operating system version, app version, and a coarse location derived from your IP address. We also work with resettable or ephemeral identifiers provided by our networks. Full treatment of these identifiers, including the Apple App Tracking Transparency framework and the consent regimes that gate them, is set out in Section 9.
2.6 Cookies and similar technologies
We use cookies and comparable technologies on the Website, and comparable application programming interfaces and local storage mechanisms in the Application, to operate the site, remember your preferences, measure performance and deliver advertising. The full breakdown by category is in Section 11.
2.7 Communications and support correspondence
If you contact us by email, telephone, post or through a contact form, we collect the content of your message, the contact details you provide, and any attachments you send. Our business support address is support@zhiruntong.com and our key accounts address is qiuwentao@zhiruntong.com. Telephone conversations with our Hong Kong SAR office may be recorded for quality and training purposes, and you will be informed at the time of recording.
2.8 Business and transaction records
In the course of IT development and consultancy, import/export & wholesale of general goods, business advisory and marketing planning, we generate records such as contracts, proposals, invoices, purchase orders, shipping documentation, customs declarations, customer and supplier due diligence files, and accounting entries. These records necessarily contain personal information about your named personnel, your company's registered contacts, and the counterparties you transact with.
2.9 Information you provide about other people
You may enter information about colleagues, suppliers, customers or members of your own organisation into the Application, or include such information in correspondence with us. Where you do so, you confirm that you have a lawful basis to share that information with us, that you have informed the person concerned, and that our processing of it is permitted by this policy. You should not enter special categories of personal information about third parties into the Application unless we have agreed a specific lawful basis in writing.
2.10 Special categories of personal information
We do not deliberately solicit special categories of personal information (such as health, biometric, racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership) through the Website or the Application, and you should not submit it. Where such information reaches us incidentally as part of a business record, or where it is strictly required to perform a contract or comply with a legal obligation, we process it under the heightened conditions described in Section 4.
3. How We Use Information
We use personal information for the following purposes. Each purpose is tied to a legal basis identified in Section 4.
- To operate and improve the Website and the Application. To load content, authenticate users, synchronise business records, store preferences, remember session state, keep the Application and the site functional, and diagnose faults.
- To deliver the services we sell. To perform IT development and consultancy engagements, to manage import/export & wholesale of general goods transactions, and to support business advisory and marketing planning work, including generating dashboards, reports, plans and export documentation from the data entered in the Application.
- To create and administer accounts. To register users, verify contact details, reset credentials, provide support, and communicate service notices such as maintenance windows, version releases and policy changes.
- To secure our systems and our users. To detect abuse, prevent fraud, investigate suspicious activity, enforce our Acceptable Use rules, and protect our intellectual property and the personal information entrusted to us.
- To measure performance. To understand which features are used, where the Application is slow or failing, how visitors navigate the Website, and how advertising performs, so that we can prioritise development and reduce waste.
- To serve advertising and monetise the Application. To display advertising, select which advertisements to serve, cap advertising frequency, and verify that an advertisement is not served more often than we have told you it will be.
- To personalise content. Where you have consented, to show you content, features, offers or advertising that is more relevant to your interests, for example your region, your language, or the business lines you use.
- To comply with law and enforce our rights. To meet tax, accounting, customs and regulatory record-keeping obligations in the Hong Kong SAR and elsewhere, to respond to lawful authority requests, and to establish or defend legal claims.
- To communicate with you. To send operational messages about the Application and the Website, and, where permitted, marketing messages about our services. Every marketing email includes an unsubscribe mechanism, and unsubscribing does not affect operational messages about accounts and services.
- To report to regulators and business partners. To report aggregate or de-identified statistics about usage, and where we are a service provider to a corporate customer, to report back to that customer within the scope they have instructed.
3.1 Aggregated and de-identified information
Where we can do so without re-identifying you, we aggregate, de-identify or pseudonymise information for analytics, capacity planning and product research. We treat aggregated and de-identified data as outside the scope of this policy once it can no longer reasonably be linked back to an individual. Where information is pseudonymised rather than fully anonymised, we keep the re-identification key under separate, restricted control and continue to apply this policy to it.
3.2 Automated decision-making
We do not use personal information to make decisions producing legal or similarly significant effects on you within the meaning of the GDPR or UK GDPR. We may use automated logic to select which advertisement is displayed, to cap the frequency of advertising, to detect fraudulent reward redemption and to prioritise support requests. Where you consider that a decision has an effect that requires human review, write to support@zhiruntong.com and we will arrange for a human to reconsider it.
4. Legal Bases for Processing
Depending on your location and the processing in question, we rely on the following legal bases. Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal. Where we rely on legitimate interests, we have carried out a balancing assessment and you may object as described in Section 12.
| Jurisdiction or framework | Legal bases relied upon | Typical application |
|---|---|---|
| GDPR (EU/EEA) | Article 6(1)(a) consent; Article 6(1)(b) performance of a contract; Article 6(1)(c) legal obligation; Article 6(1)(d) vital interests; Article 6(1)(f) legitimate interests | Account operation, service delivery, advertising consent and opt-out records, security logging, statutory record-keeping |
| UK GDPR and Data Protection Act 2018 | Consent, contract, legal obligation, vital interests, public task and legitimate interests, as adopted by UK law | Mirror of the EU position for users in the United Kingdom, including UK-specific cookie and advertising consent management |
| CCPA and CPRA (California) | Notice at collection; contractual necessity; statutory and regulatory obligation; legitimate interests; sale and sharing are treated as regulated disclosures requiring opt-out | Right to know, right to delete, right to correct, opt-out of sale or sharing, limitation of use of sensitive personal information, and non-discrimination |
| Virginia VCDPA | Consent, contractual necessity, statutory obligation, legitimate interests, and explicit consent for targeted advertising | Opt-out of targeted advertising, data protection assessments, and data minimisation obligations |
| Colorado CPA | Consent, contractual necessity, statutory obligation, legitimate interests, and universal opt-out mechanism recognition | Profiling and targeted advertising opt-out, consent for sensitive data, and recognition of Global Privacy Control |
| Connecticut CTDPA | Consent, contractual necessity, statutory obligation, legitimate interests, and opt-out mechanisms for targeted advertising and profiling | Sale of personal data, targeted advertising opt-out, and children's data safeguards |
| Utah UCPA | Consent, contractual necessity, statutory obligation, legitimate interests, and sensitive-data consent | Opt-out of sale, targeted advertising and processing of sensitive data, with a restricted processing allowance |
| Texas TDPSA | Consent, contractual necessity, statutory obligation, legitimate interests, and opt-out of targeted advertising, sale and profiling | Data protection assessments, limited disclosure of sensitive data, and honouring opt-out preference signals |
| Oregon OCPA | Consent, contractual necessity, statutory obligation, legitimate interests, and consumer preference signals such as Global Privacy Control | Opt-out of targeted advertising, sale, and profiling; data minimisation; and universal opt-out mechanism recognition |
| LGPD (Brazil) | Consent for the processing activity, compliance with legal or regulatory obligation, legitimate interest with the balancing test, protection of life, and routine exercise of rights | Rights of confirmation, access, correction, anonymisation, blocking, deletion, portability, information on sharing and review of automated decisions |
| PIPEDA (Canada) | Consent, contract, legal obligation, and reasonable security and fraud-prevention purposes under the accountability principle | Meaningful consent, limited collection and use, safeguards, and access and correction requests |
| Australia — Privacy Act 1988 and Australian Privacy Principles | Consent, contract, legal obligation, permitted general situation, and reasonably necessary enforcement-related uses | APP transparency, collection, use and disclosure limitation, security, accessibility, and correction and complaint handling |
| PDPA (Singapore) | Consent, contract, legal obligation, and legitimate interests evaluated through the reasonable-purpose test and comparable-to-consent standard | Notification and consent, purpose limitation, protection obligation, retention limitation, transfer limitation, and data-subject access |
| DPDP Act 2023 (India) | Consent, voluntary provision for a contract or service, performance of a legal obligation, and certain state-specified legitimate uses | Notice in clear language, data fiduciary obligations, grievance redressal, and rights of access, correction, erasure and nomination |
| APPI (Japan) | Consent, contract necessity, legal obligation, and the aggregate of interests recognised by the PPC | Properly obtained personal information, specified purpose of use, third-party provision, cross-border transfer disclosure, and pseudonymised information handling |
| PIPA (South Korea) | Consent, contract, legal obligation, and legitimate interests; separate consent for marketing and for sensitive data | Restricted processing and disclosure measures, security measures, retention periods, data-subject rights, and overseas transfer management |
| Other regions | Consent, contract, legal obligation, vital interests, and legitimate interests, applied according to the laws of the jurisdiction in which the user is located | General standard applied where no specific regime is listed above, and local adaptations made where a local law provides a higher level of protection |
4.1 Consent and how to withdraw it
Where processing is based on consent, you may withdraw that consent at any time, in the Website consent panel or through your device settings for the Application. Withdrawal is as easy as giving consent. On withdrawal we stop the processing concerned, delete or deactivate the associated consent record, and adjust our advertising and analytics configuration accordingly. Most processing in this policy does not depend on consent; where it does, the relevant toggle is clearly labelled.
4.2 Legitimate interests and your right to object
Where we rely on legitimate interests, our interest is the efficient and secure operation of the Website and the Application, the protection of our systems and our users' data, the prevention of fraud, the fulfilment of commercial obligations, and the continued viability of a business that provides IT development and consultancy, import/export & wholesale of general goods, business advisory and marketing planning. We assess necessity and balancing before relying on the basis, and we stop or adapt the processing if your interests outweigh ours. You can object on legitimate-interest grounds in the jurisdictions where that right applies, as set out in Section 12.
4.3 Higher conditions for sensitive data
Where special categories of personal information are processed incidentally, we do so only with explicit consent, where processing is necessary for the establishment, exercise or defence of legal claims, or where the processing is manifestly made public by you. We apply additional access controls, and we do not use such data for advertising profiling.
5. Sharing and Processors
We share personal information only for the purposes described in this policy, and only with recipients that need it for those purposes. We do not sell personal information for money. Where a disclosure is a "sale" or "sharing" under California law, we treat it as such, provide the required notice, and honour valid opt-out preference signals including Global Privacy Control.
5.1 Service providers and processors
We engage service providers that host our infrastructure, deliver email, operate customer support tooling, provide analytics and crash reporting, process payments, manage our corporate records, and supply professional advice. These providers act on our documented instructions, are bound by contract to process data only as instructed, to protect it appropriately, and to assist us with the rights requests described in Section 12. A list of the material categories of processors is available on request to support@zhiruntong.com.
5.2 Advertising and measurement networks
The Application is supported by advertising. Advertising partners act as independent controllers for the data they collect, on their own legal bases and subject to their own privacy policies. The full list of platforms, the purposes for which each is used, and the link to each platform's opt-out mechanism are set out in Section 9.
5.3 App store and platform partners
The Application is distributed through the Apple App Store and Google Play. Apple and Google act as independent controllers for the data they collect in the course of distribution, installation, purchase, payment and account management. Their processing is governed by their respective privacy policies and platform terms, and it is a precondition of distribution that we make our disclosures available through the store listing. We also use the platform attribution and analytics services that each store provides to publishers, subject to their terms.
5.4 Professional advisers, auditors and authorities
We disclose personal information to our auditors, accountants, legal advisers, insurers, banks and professional advisers where necessary for the performance of their role, and to regulators, courts, tax authorities, customs authorities and law enforcement bodies where we are required to do so or where disclosure is necessary to protect our rights or the safety of any person.
5.5 Business and corporate transfers
Personal information may be transferred as part of a merger, acquisition, reorganisation, financing or sale of assets involving HK ZANVIX CO., LIMITED or a business line, including the Application. If such a transfer occurs, we will provide prior notice where the law requires it, and the recipient will be bound by this policy or by an equivalent standard, or you will be given notice and the opportunity to object or withdraw where that is the applicable remedy.
5.6 Disclosure required by law
Where we are compelled to disclose personal information, we will disclose only the portion legally required, notify you where the law permits us to do so, and cooperate with any lawful challenge to the request.
6. International Transfers
Our Hong Kong SAR office is our principal place of business, but the Application is downloaded globally, our advertising and measurement providers operate internationally, and some of our service providers process data outside the Hong Kong SAR. International transfers of personal information are therefore a regular part of our operations, and we manage them deliberately.
6.1 Transfer mechanisms
- EU to third countries. Transfers from the European Economic Area are made under an adequacy decision issued by the European Commission where one exists for the destination, or otherwise under the Standard Contractual Clauses (SCCs) adopted by the European Commission, including the modules applicable to controller-to-processor and controller-to-controller transfers.
- United Kingdom to third countries. Transfers from the United Kingdom are made under the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or the UK IDTA or Addendum together with the UK IDTA or Addendum's accompanying guidance.
- Other jurisdictions. Where the relevant regime requires a specific mechanism, such as a binding corporate rules scheme or a consent-based transfer, we apply that mechanism in addition to the contractual safeguards above.
6.2 Adequacy decisions
Where the European Commission or the UK Secretary of State has issued an adequacy decision covering the destination and the relevant processing, we rely on that decision rather than on supplementary contractual clauses, and we verify that the decision has not been suspended, invalidated or amended before relying on it.
6.3 Transfer impact assessments (TIA)
Before relying on Standard Contractual Clauses, the UK IDTA or the UK Addendum, we conduct a transfer impact assessment for the destination and the receiving processor, covering local law access, encryption in transit and at rest, the sensitivity of the data, the retention period, the security incident history of the recipient, and the supervisory-authority landscape. Where the assessment indicates a material risk that cannot be mitigated by technical or organisational measures, we do not proceed with the transfer, or we suspend it.
6.4 Data residency
Where a customer engages us for IT development and consultancy or business advisory and marketing planning and that engagement requires data to remain in a particular jurisdiction, we will configure the applicable hosted components to meet that requirement and record it in the engagement documentation. Business records held for import/export & wholesale of general goods activity are retained in accordance with the record-keeping obligations described in Section 7 and are made available to the customer on whose behalf they were generated.
6.5 Onward transfers and sub-processors
Where we transfer personal information to a processor, that processor must not transfer it onward without our authorisation. Where an onward transfer is necessary, the same safeguards apply, and we maintain a current sub-processor list that is available on request. We apply the same transfer discipline to the Application, whose development and analytics partners may operate from several countries.
7. Retention
We keep personal information only for as long as we need it for the purposes for which we collected it, for longer where the law requires it, and no longer. When a period expires, we delete the information or irreversibly anonymise it. The periods below are our default schedule; specific contractual commitments or statutory retention obligations override them.
| Data category | Default retention period | Basis for the period |
|---|---|---|
| Account and registration data | Duration of the account, plus 24 months after closure | Account administration, support continuity and the defence of claims |
| Authentication records and security logs | 12 months | Detection of account compromise, fraud and abuse |
| Billing, invoice and accounting records | 7 years from the end of the accounting period | Hong Kong SAR tax and business record-keeping requirements, and audit obligations |
| Contracts, proposals and purchase orders | 7 years from the date of the agreement | Enforcement of contractual rights and regulatory record-keeping |
| Customs declarations and import/export documentation | 7 years from the date of import or export | Customs, excise and trade-compliance audit requirements |
| Raw usage and interaction event logs | 13 months | Product analytics, security review and capacity planning |
| Aggregated analytics and statistics | 36 months | Longitudinal performance measurement, in de-identified or aggregated form |
| Crash and diagnostic data | 90 days | Stability analysis and fault isolation |
| Advertising identifiers and advertising event logs | 13 months | Frequency capping, fraud detection, and demonstrating compliance with consent and opt-out instructions |
| Consent and opt-out records | 6 years from the last interaction | Evidence of compliance with consent, preference-signal and opt-out obligations |
| Cookie and preference storage | 12 months, or until you clear or change the setting | Consent management, preference persistence and proof of consent |
| Rewarded-ad redemption records | 24 months | Reward fulfilment integrity, dispute handling and anti-fraud review |
| Optional location data | The duration of the session, and 30 days in aggregated form | Feature functionality and aggregate logistics analysis |
| Website server logs | 12 months | Security, availability, and investigation of abuse or errors |
| Correspondence with us | 36 months from the last substantive exchange | Customer relationship continuity and resolution of disputes |
| Data subject rights request records | 6 years | Evidence that we answered requests correctly and on time |
| Regulatory and compliance correspondence | 7 years | Supervisory, licensing and record-keeping obligations |
7.1 Deletion and anonymisation
Deletion in practice means removing the information from active systems within a short operational window and from backups on the next routine backup cycle, after which it can no longer be restored in the ordinary course. Where full physical deletion from backups would require disproportionate effort, we instead isolate the data so that it cannot be used for any other purpose, and we delete it as backups expire. Where anonymisation is an appropriate substitute, we apply it irreversibly and treat the result as no longer being personal information.
7.2 Legal holds
Where we are required to preserve information for a legal claim, a regulatory investigation or a customs audit, we suspend the relevant deletion period for as long as the requirement applies, restrict the information to the people who need it for that purpose, and inform you where the law permits.
8. Security
We apply a layered approach to protecting personal information, and we do not treat any single measure as sufficient on its own.
8.1 Encryption
All traffic between your device and our servers is protected with TLS, with older protocol versions and weak cipher suites disabled. Sensitive data stored at rest, including credentials, payment-related records and customer business records, is encrypted. Encryption keys are managed separately from the data they protect, and access to key material is restricted and logged.
8.2 Access control
Access to personal information is granted on the basis of role and need, is reviewed periodically, and is revoked promptly when a person changes role or leaves the business. All administrative access requires multi-factor authentication. Production data is not copied into non-production environments for testing unless it has first been de-identified. We log access to customer records and review those logs.
8.3 Platform and application protections
The Application is distributed through the Apple App Store and Google Play, and benefits from the platform protections those stores apply, including signed distribution, platform permission controls, and review processes. We request only the permissions the Application actually needs, we explain the purpose of each permission at the point it is requested, and we do not repurpose a permission after it has been granted.
8.4 Secure development
Our development practices include code review, dependency and vulnerability scanning, secret management that keeps credentials out of source control, and testing that specifically covers authorisation, access control and injection risks. Where a security issue is identified, we prioritise remediation according to severity and user impact.
8.5 Incident response
We maintain a documented incident response plan covering detection, containment, eradication, recovery and notification. If a personal information breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority within 72 hours where the GDPR or UK GDPR applies, and we will notify affected individuals where the law requires it and where the risk is high. We will also tell you about a breach that materially affects the services we provide to your organisation, in line with our contractual commitments.
8.6 Limits of security
No method of transmission or storage is completely secure. We work to industry standards and to the requirements of applicable law, but you should use a unique password for your account, protect the device on which the Application is installed, and tell us promptly if you believe your credentials have been compromised.
9. Advertising and Monetisation
The Application is supported by advertising. To keep the Application available at the price we offer it, and to fund the IT development and consultancy, import/export & wholesale of general goods and business advisory and marketing planning services we deliver, the Application integrates third-party advertising software development kits. These SDKs may collect device identifiers, usage information and advertising data as described in Section 2, and they may share that data with the other businesses in their own networks. We do not permit our advertising partners to use the personal information we provide to them for purposes outside the advertising relationship.
9.1 Advertising platforms, purposes and opt-out mechanisms
The table below lists the advertising platforms that may be present in the Application, the purposes for which each is integrated and the data each may use, and a link to the platform's own opt-out mechanism. Opting out on a platform's own page stops that platform from serving you further interest-based advertising through its own systems; it may not immediately remove data already processed. Where you would rather opt out centrally, we also honour Global Privacy Control, as described in Section 15.
| Platform | Purpose / Data Used | Opt-out |
|---|---|---|
| Google AdMob | Ad serving and mediation, frequency capping and revenue reporting; advertising identifier, coarse location, device and app version data | Opt out |
| Google Ad Manager | Ad delivery for publishers and campaigns, advertising measurement; advertising identifier, coarse location, device and app version data | Opt out |
| Meta Audience Network | Banner, interstitial and rewarded video advertising; advertising identifier, device and app version data, engagement and performance events | Opt out |
| Unity Ads | In-app video and banner advertising, campaign measurement; advertising identifier, device and app version data | Opt out |
| AppLovin | Ad mediation and rewarded video advertising; advertising identifier, device and app version data, ad interaction events | Opt out |
| ironSource (LevelPlay) | Mediation and waterfall or bidding mediation across demand sources; advertising identifier, device and app version data, impression and revenue events | Opt out |
| Vungle/Liftoff | Rewarded and interstitial video advertising; advertising identifier, device and app version data, ad engagement events | Opt out |
| Pangle (TikTok for Business) | Video and interstitial advertising, campaign measurement; advertising identifier, device and app version data, interaction events | Opt out |
| Mintegral | App open, interstitial and rewarded video advertising; advertising identifier, device and app version data, install attribution | Opt out |
| Chartboost | Rewarded video and interstitial advertising, install attribution; advertising identifier, device and app version data, campaign events | Opt out |
| AdColony | Video advertising and app open formats; advertising identifier, device and app version data, impression events | Opt out |
| InMobi | Interstitial, banner and rewarded video advertising; advertising identifier, device and app version data, inferred location and engagement data | Opt out |
| Amazon Ads | Advertising on Amazon properties and third-party app inventory; advertising identifier, device and app version data, purchase and interest signals | Opt out |
| Digital Turbine | Offerwall and app discovery advertising; advertising identifier, device and app version data, install and conversion events | Opt out |
| Smaato | Mediated banner, interstitial and native advertising; advertising identifier, device and app version data, impression events | Opt out |
| Fyber | Marketplace mediation for rewarded video and interstitial formats; advertising identifier, device and app version data, ad engagement events | Opt out |
| Ogury | Data-enriched advertising and audience segmentation; advertising identifier, device and app version data, engagement signals | Opt out |
| Criteo | Retargeting, dynamic creative and commerce advertising; advertising identifier, device and app version data, browsing and purchase signals | Opt out |
| Teads | Native and video advertising across publisher inventory; advertising identifier, device and app version data, contextual signals | Opt out |
| Moloco | Machine-learning driven advertising auction and retargeting; advertising identifier, device and app version data, event signals | Opt out |
| PubMatic | Programmatic ad serving, header bidding and audience management; advertising identifier, device and app version data, page and event signals | Opt out |
| Magnite | Programmatic exchange and yield management; advertising identifier, device and app version data, auction and impression events | Opt out |
9.2 Personalised and non-personalised advertising
Personalised advertising means advertising selected using information about you, such as your advertising identifier, your inferred interests, your prior interactions with the Application, or your approximate location. We serve personalised advertising only where the law permits it and where you have given the consent or made the opt-out choice that the law requires in your jurisdiction. Non-personalised advertising means advertising selected on contextual factors such as the content of the screen, the country you are in, the language of your device and the time of day, without building a profile of you. We serve non-personalised advertising more widely, including to users who have declined personalised advertising or advertising generally. You can also ask us to serve you non-personalised advertising by contacting support@zhiruntong.com.
9.3 Consent for advertising
In the European Economic Area, the United Kingdom, Switzerland and other jurisdictions requiring prior consent for storage or access on your device, we present an advertising consent notice before any non-essential cookies, SDKs or advertising identifiers are set. We use an industry-standard consent management platform that remembers your choice, and we treat a refusal as a valid signal: refusing means no personalised advertising, no cross-site tracking pixels on the Website, and no advertising identifiers passed to networks for interest-based purposes. We do not use consent for personalised advertising as a condition of access to the Application's core business functionality, including the tools our corporate customers use to manage IT development and consultancy, import/export & wholesale of general goods and business advisory and marketing planning workflows.
In California and other US states with comprehensive privacy legislation, we provide a "Do Not Sell or Share My Personal Information" or equivalent control and honour it as a valid opt-out request. Where that choice is expressed through Global Privacy Control, we treat the signal as a valid request to opt out of sale, sharing and targeted advertising.
9.4 Apple App Tracking Transparency
On iOS, Apple's App Tracking Transparency framework requires a permission prompt before an app may track you across other companies' apps and websites. Where the Application requests tracking permission, the system prompt appears at that moment, and it is not shown on your behalf by us. If you decline the prompt, we do not pass your advertising identifier to advertising networks for tracking purposes, we do not build cross-application profiles, and you receive contextual advertising instead. You can change your answer later in your device settings, under Privacy & Security, then Tracking, and we respect the updated setting at the next Application launch.
9.5 AAID and IDFA
On Android, the Google Advertising ID (AAID) is a resettable identifier that you can reset or delete through your device settings, and Android provides a "Delete advertising ID" control. On iOS, the IDFA is available only after you have authorised tracking. We treat a reset or deletion of either identifier as a signal that the account should no longer receive personalised advertising, and we propagate that instruction to our mediation layer. We do not attempt to re-create a reset identifier through fingerprinting, and we do not combine a reset identifier with other data to re-identify you.
9.6 Advertising controls available to you
Beyond the opt-out links in the table above, you can: decline the advertising consent prompt or the ATT prompt; reset or delete your advertising identifier in your device settings; limit ad tracking through your operating system's privacy settings; enable a network-level ad blocker; or ask us directly to place your device on a do-not-serve list for personalised advertising, by writing to support@zhiruntong.com. We note which of these controls is available on your platform and device, and we will tell you if a particular control is not supported.
10. Advertising Formats and User Controls
The Application may display the advertising formats described below. We describe each one plainly so that you know what you are seeing and what you can do about it.
| Format | Description | User Control |
|---|---|---|
| App Open | A full-screen advertisement displayed when the Application launches, before you reach the content you opened the Application for. It is typically a short, skippable creative of a few seconds. | Clearly marked and dismissible with a close control; frequency limited so that it does not appear on every launch; served as contextual advertising where you have declined personalised advertising or advertising consent |
| Rewarded Video | A full-screen video advertisement that you choose to watch in exchange for a reward such as a report export, an extended analytics view, or a discount on a commercial subscription. No reward is granted unless the advertisement is completed or the reward terms are met. | Strictly opt-in; never played automatically; the reward terms are shown before you commit; a close control is available where the platform permits and the creative allows |
| Interstitial | A full-screen advertisement shown at a natural transition between screens or pieces of content, for example after a record is saved or a report is generated. | Clearly marked with a close or skip control; frequency capped to avoid interrupting a workflow repeatedly; never shown during a transaction in progress |
| Banner | A rectangular advertisement displayed within a defined area of a screen, either at the top, the bottom, or in a dedicated in-content slot. | Placed so that it does not obscure navigation or primary controls; collapsible where the creative permits; not served to users who have opted out of personalised advertising |
10.1 Principles we apply to advertising in the Application
- No advertisement is presented as part of the content of a business document, report or export, or in a way that could be mistaken for an instruction from us.
- No advertisement misrepresents our own products or services, and no advertisement contains a deceptive button or a deceptive call to action.
- No advertisement is served to a child or to a device we have reason to believe belongs to a child, as further described in Section 13.
- We do not use advertising to collect information that would be unreasonable or misleading if you were told that we were collecting it.
- We do not use sensitive data, including health, precise location or financial account data, to build advertising profiles.
- Rewarded advertising is never used in a way that exploits cognitive impairment, and reward terms are clear enough to be understood before the advertisement begins.
11. Cookies and Similar Technologies
We use cookies and comparable technologies on the Website, and local storage and comparable technologies in the Application, for four distinct purposes. Each category is described below, together with the control you have over it.
| Category | What it does | Examples | Control |
|---|---|---|---|
| Essential | Required for the Website or the Application to function at all. These technologies carry no advertising function and cannot be switched off without breaking the service. | Session cookie, load balancer cookie, consent preference record, security and anti-fraud token | Always active. Required for the service to operate |
| Functional | Remembers choices you make so that we do not have to ask again on every visit, such as your region, language and interface preferences. | Language selection, remembered region for content and availability, interface and display preferences | Optional. Manageable from the cookie panel or your browser settings |
| Analytics | Measures how the Website and the Application are used so that we can find errors, understand which features matter, and improve performance. | Page view counts, session duration, feature usage events, crash and error reporting, approximate performance metrics | Optional. Blocked until you consent where consent is required |
| Advertising | Supports the delivery, capping, measurement and frequency control of advertising, including interest-based advertising where you have permitted it. | Advertising identifier, conversion pixels, attribution parameters, ad impression and click events, frequency capping cookies, retargeting tags | Optional. Requires consent in applicable jurisdictions; controllable via the opt-out links in Section 9 and Global Privacy Control |
11.1 Consent management
Where consent is required, we present a consent panel on your first visit to the Website, and an equivalent prompt in the Application where the platform requires one. The panel lets you accept all categories, accept only the necessary ones, or reject optional categories, and it lets you change your decision at any time through the cookie settings link in the footer of the Website or the privacy settings section of the Application. Where you reject optional technologies, we do not load them at all, we do not attempt to identify you through alternative means, and the core functionality of the Application remains available to corporate customers using it for IT development and consultancy, import/export & wholesale of general goods and business advisory and marketing planning.
11.2 Duration and browser controls
Session cookies are deleted when you close your browser. Persistent cookies are retained for the periods set out in Section 7 and are visible to you in your browser's cookie storage. You can delete or block cookies through your browser settings at any time, and blocking essential cookies will prevent some parts of the Website from working. Where the Website is embedded in a mobile application web view, the host application's storage settings apply in addition to your browser settings.
12. Regional Rights
Depending on where you live, you may hold rights over your personal information beyond the right to complain. We extend our core rights — access, correction, deletion, restriction, portability and objection — to every user regardless of jurisdiction, and we add the region-specific rights set out in the table below. To exercise any right, contact support@zhiruntong.com. We will confirm receipt, verify your identity so that we do not disclose your information to the wrong person, and respond within the period required by the law that applies to you.
| Region | Rights | How to Exercise |
|---|---|---|
| EU/EEA | Access, rectification, erasure, restriction of processing, data portability, objection (including objection to direct marketing and to processing based on legitimate interests), withdrawal of consent at any time, and the right to complain to a supervisory authority in your country of residence | Email support@zhiruntong.com with the subject line "Data Rights Request". We respond within one month, extendable by two further months for complex requests where we tell you why |
| United Kingdom | Access, rectification, erasure, restriction, portability, objection, withdrawal of consent, and the right to complain to the Information Commissioner's Office | Email support@zhiruntong.com. Complaints to the ICO remain available at any time and do not affect your right to seek a remedy |
| United States (state law by state reference) | Under the CCPA and CPRA: the right to know and access, the right to delete, the right to correct, the right to opt out of sale or sharing for cross-context behavioural advertising, the right to limit use and disclosure of sensitive personal information, the right to non-discrimination for exercising rights, and the right to be free from unlawful discrimination. Comparable rights are provided under the Virginia VCDPA, Colorado CPA, Connecticut CTDPA, Utah UCPA, Texas TDPSA and Oregon OCPA, including opt-outs of targeted advertising, sale and profiling, and the right to appeal a denied request | Email support@zhiruntong.com. Submit a Global Privacy Control signal or use our "Do Not Sell or Share My Personal Information" control, and we treat it as a valid opt-out request |
| Brazil | Confirmation of the existence of processing, access to data, correction of incomplete or outdated data, anonymisation, blocking or deletion of unnecessarily processed or unlawfully processed data, portability, deletion of data processed with consent where consent is withdrawn, information on the entities with which data is shared, information on the possibility of refusing consent and the consequences of refusal, and review of decisions made solely by automated processing | Email support@zhiruntong.com. We respond in accordance with the LGPD timetable and you may bring proceedings before the ANPD |
| Canada | Access, correction, withdrawal of consent, and confirmation that personal information is used for appropriate purposes only, in line with PIPEDA and the accountability principle | Email support@zhiruntong.com. We respond with a record of the request, as required by PIPEDA principle 4 |
| Australia | Australian Privacy Principles rights of transparency, collection, use, disclosure and storage limitation, security, accessibility, and correction, including correction of inaccurate, out-of-date, incomplete or misleading information | Email support@zhiruntong.com. You may also complain to the Office of the Australian Information Commissioner |
| Singapore | Notification and consent, purpose limitation, protection, retention limitation, transfer limitation, and data-subject rights of access and correction, together with the right to withdraw consent and to have data protection cease | Email support@zhiruntong.com. We respond within the period specified in the PDPA and its regulations |
| Japan | Disclosure of the purposes of use, disclosure of the name of the personal information control entity and the personal information handling manager, requests for disclosure, correction, cessation of use, and deletion, and suspension of provision to third parties | Email support@zhiruntong.com. Requests are handled in line with the Personal Information Protection Commission guidance |
| South Korea | Access, correction, deletion, suspension of processing, withdrawal of consent, objection to processing including automated decision-making, and rights concerning the outsourcing and overseas transfer of personal information | Email support@zhiruntong.com. We provide a record of our handling of the request as required by PIPA |
| India | Access to information, correction and completion, erasure of information, grievance redressal, and the right to nominate another person in the event of death or incapacity | Email support@zhiruntong.com or use the grievance contact in our written communications. We acknowledge grievances and resolve them within the period specified under the DPDP Act 2023 |
| Other Regions | Access, correction, deletion, withdrawal of consent, and objection, in each case to the extent required by the law of your country of residence, residence or nationality | Email support@zhiruntong.com. We apply the highest level of protection available to you under the law that applies to you |
12.1 How we handle a rights request
We verify the identity of the requester before disclosing information, using the information already held and, where the request concerns a particular record, a challenge to the requester. We will not ask for excessive identification information. We aim to acknowledge a request within three business days and to resolve it within the statutory period for your jurisdiction. If we need more time, or if we need to clarify the request, we will tell you and explain why.
12.2 Appeals and complaints
If we decline a request, we explain why and describe any complaint route available to you. Where a law provides a right of appeal, you may ask us to reconsider, and a different member of our team will review the decision. If you remain dissatisfied, you may complain to the relevant supervisory authority, and in the United Kingdom, Hong Kong SAR, European Union, Brazil, Canada or Australia, to the authority for your jurisdiction.
12.3 No discrimination
We do not penalise you, charge you a different price, or degrade your service because you have exercised a privacy right, because you have declined optional advertising, or because you have withdrawn consent. The Application continues to provide its business functionality after a privacy choice, including for corporate customers relying on it for IT development and consultancy, import/export & wholesale of general goods and business advisory and marketing planning.
12.4 Authorised agents
Where the law allows you to appoint an authorised agent to make a request on your behalf, we will ask for proof of that authority, and we may require confirmation from you directly. We may refuse a request made by an agent where the law permits us to do so, and we will explain the reason and tell you how to make the request yourself.
13. Children's Privacy
HK ZANVIX CO., LIMITED does not knowingly collect personal information from children, and we do not knowingly direct advertising to children. The Application is a business productivity tool for organisations and adults, and the Website is published for business audiences.
13.1 COPPA (United States)
The Children's Online Privacy Protection Act and its implementing rule prohibit operators of websites or online services directed to children under 13, or of general-audience services with actual knowledge that they are collecting personal information from a child under 13, from collecting such information without verifiable parental consent. We do not knowingly collect personal information from children under 13. We do not knowingly serve interest-based advertising to children under 13, and the advertising platforms listed in Section 9 are not permitted to serve advertising that is selected using personal information from a child.
13.2 GDPR and UK GDPR age thresholds
Under the GDPR and the UK GDPR, the age of digital consent is 16 in each case, and a lower age of 13 may be permitted where a Member State or the United Kingdom has legislated for it, provided that the lower threshold applies to information society services provided directly to a child. Where we are offered an age in that way, we apply it and we apply an age-appropriate design standard. Where a user is below the applicable threshold, we do not knowingly collect personal information without authorisation from the holder of parental responsibility, and we do not knowingly serve personalised advertising to them.
13.3 Store age ratings and safeguards
The Application carries an age rating on the Apple App Store and Google Play consistent with its intended audience and with the content it contains. We maintain those ratings, and we review them whenever the Application's content changes materially. We apply the platform children's policies as described in Section 14, and we configure our advertising mediation so that child-directed or child-appropriate treatment is applied where the platform requires it.
13.4 If we learn that we have collected a child's information
Where we discover that we have inadvertently collected personal information from a child below the applicable threshold, we delete it as quickly as possible. If you believe that this has happened, contact support@zhiruntong.com and we will investigate, and we will remove the information and confirm to you once we have done so.
14. App Store Compliance
We are committed to meeting the privacy and content standards of the platforms on which the Application is distributed. This is not only a condition of distribution; it is how we have chosen to build the product.
14.1 Apple App Store Review Guidelines
The Application complies with the Apple App Store Review Guidelines, including Guideline 5.1 (Privacy), which requires an accurate privacy policy linked from the App Store listing, a privacy nutrition label that accurately describes the data collected and the purposes of collection, permission requests made only for functionality that is genuinely required, and prior consent for tracking under App Tracking Transparency. We do not sell personal information, we do not use data for purposes outside our stated privacy policy, and we do not attempt to identify the model or the individual user of the device for analytics.
14.2 Apple Kids Category
The Application is not designed for children and is not submitted to the Apple Kids Category. We do not include content or advertising inappropriate for children, and we do not knowingly collect personal information from children. If a future version of the Application were to be submitted to the Kids Category, it would be built to the additional requirements of the Kids Category, including the heightened privacy, parental consent and advertising restrictions that category imposes.
14.3 Google Play Data Safety
The Application's Google Play Data Safety form accurately describes the data it collects, whether that data is encrypted in transit, whether users can request that their data is deleted, and whether data is shared with third parties. We keep that form in step with the Application's actual behaviour and with this policy, and we re-review it before any release that changes data practices.
14.4 Google Play Families policy
The Application complies with the Google Play Families policy and with the Families advertising requirements where they apply, including the restrictions on advertising identifiers and personalised advertising for child-directed content, and the requirement to use the self-certified SDK list where an approved alternative exists.
14.5 Our commitment
If a platform changes its requirements, or if we identify a practice that does not meet the standard we have set out in this policy, we will update the Application and this policy accordingly. We do not treat store approval as a substitute for our own compliance; our own standard is that we collect no more than we need, we explain it plainly, and we give you a workable way to say no.
15. Do Not Track and Global Privacy Control
Do Not Track (DNT) is a legacy browser mechanism that has not achieved adoption as an industry standard and has no agreed legal effect in most jurisdictions. We do not respond to Do Not Track signals.
Global Privacy Control (GPC) is a different mechanism, and it is recognised as a valid request to opt out of sale, sharing and targeted advertising in California and in a growing number of other US states and jurisdictions. Where a GPC signal is received, we treat it as a valid opt-out request for that device or browser, apply it across our advertising configuration, and do not serve personalised advertising or share personal information for cross-context behavioural advertising through it. We also honour equivalent signals, consent strings and opt-out mechanisms provided by the operating system, the browser or the advertising platform in question.
If you would like personalised advertising to stop on a particular device, the most reliable method is to send a GPC signal, to use the "Do Not Sell or Share" control, to decline the consent prompt, or to reset your advertising identifier. We do not ask you to make a particular request to a specific platform unless you want to go further and switch that platform off entirely.
16. Changes to This Policy
We review this policy at least annually, and more often when we make a material change to the Application, to our processing, to our service providers, or when the law changes. When we make a change, we will:
- update the "Last Updated" date shown at the top of this policy and in Section 18;
- describe the change in a notice on the Website and, where the Application has a notification surface, in the Application itself, before the change takes effect;
- where the change is material, provide the notice at least 14 days before it takes effect, and for changes to the purposes of processing or to the categories of personal information we use for advertising, provide at least 30 days' notice;
- request fresh consent where the law requires it, and where consent is withdrawn or changes, adjust the configuration of the Website and the Application accordingly from that point forward;
- keep the previous versions of this policy available on request, so that you can see what changed and when.
16.1 Continued use
If you continue to use the Website or the Application after a change to this policy takes effect, you are treated as having accepted the updated policy. Where the law requires your consent to a change, we will ask for it, and your continued use will not be treated as consent where the law prohibits that inference.
17. Contact Us
HK ZANVIX CO., LIMITED is the controller for the personal information described in this policy. Our contact details are:
- Company: HK ZANVIX CO., LIMITED
- Office: Room 701 (Unit 127), 7/F, Tower B, New Mandarin Plaza, 14 Science Museum Road, Tsim Sha Tsui East, Hong Kong
- Website: zhiruntong.com
- Business support: support@zhiruntong.com
- Key accounts: qiuwentao@zhiruntong.com
17.1 Privacy requests
Send all privacy requests, questions about this policy, consent withdrawals and complaints to support@zhiruntong.com. Please include the subject line "Data Rights Request" where your message concerns a rights request, so that it reaches the correct team promptly. For matters relating to your account specifically, you may also contact qiuwentao@zhiruntong.com.
17.2 What to include
To help us locate your information, please tell us the email address or the Application identifier associated with your account, the right you wish to exercise, and the date range or categories of information concerned. Do not send passwords, full payment card numbers, identity document numbers or other sensitive credentials in an initial request.
17.3 Complaints
If you are not satisfied with our response, you may ask us to reconsider, or complain to the data protection authority for your jurisdiction. In the Hong Kong SAR, the relevant authority is the Office of the Privacy Commissioner for Personal Data; in the European Union and the United Kingdom, you may complain to the supervisory authority in your country of residence.
18. Effective Date
This Privacy Policy takes effect on the Effective Date stated above and applies to all processing carried out by HK ZANVIX CO., LIMITED from that date. It replaces any earlier privacy notice, website privacy statement or in-application notice previously published by us in respect of the Website or the mobile management application distributed through the Apple App Store and Google Play.
Where a specific engagement between HK ZANVIX CO., LIMITED and a customer includes data processing terms, those terms apply in addition to this policy and prevail over it in the event of conflict, provided that they do not reduce any protection you hold under applicable law. This policy should be read together with our Terms of Service, which govern your use of the Website and the Application.