Privacy Policy
This policy explains what personal data QiLuck (operated by 义乌市岐鄢电子商务商行, 中国浙江省义乌市稠江街道大路金小区) collects, why, how long we keep it, and the rights you have. Target audience: United States, United Kingdom, Canada, Australia, Singapore, Malaysia, Hong Kong SAR (China) and Taiwan (China).
1. Who we are (data controller)
Operator: 义乌市岐鄢电子商务商行
Postal address: 中国浙江省义乌市稠江街道大路金小区
Contact for privacy matters:
support@qiluck.com
2. What we collect & why (lawful basis)
| Data | Purpose | Lawful basis (GDPR) |
|---|---|---|
| Email, display name, password hash | Account, orders, order emails | Contract (Art. 6(1)(b)) |
| Quiz answers & resulting element | Your element profile & recommendations | Consent (Art. 6(1)(a)) — quiz consent checkbox |
| Birth date, hour, time zone (optional, birth-mode only) | Generate your BaZi-based reading | Explicit consent (Art. 9 conditions / Art. 6(1)(a)) — separate checkbox |
| Orders & purchases (items, amounts, status) | Fulfilment, receipts, refunds, tax & dispute records | Contract + legal obligation (Art. 6(1)(b)/(c)) |
| Shipping address (physical items only) | Delivery | Contract |
| Delivery phone number (physical items only) | Carrier contact for delivery and customs clearance; notifying you of a delivery problem | Contract (Art. 6(1)(b)) |
| Saved addresses (optional — if you choose to save them) | Filling in your shipping details at checkout so you don’t have to re-type them; you can add, edit or delete them at any time in My Account → My addresses | Consent (Art. 6(1)(a)) — withdrawn by deleting the address |
| Email engagement (unsubscribes, send logs) | Honour opt-outs; CAN-SPAM / PECR compliance | Legal obligation / legitimate interests |
| Cookie consent record (category, timestamp) | Proof of consent (ePrivacy) | Legal obligation |
| Security & server logs (hashed UA fingerprint) | Abuse prevention, security | Legitimate interests (Art. 6(1)(f)) |
| Anonymous visit statistics — see §3a No IP address, no full user-agent string, no name or contact detail. A one-way hash is used purely to count a visit once and is regenerated every calendar day. | Counting visits and understanding which channels bring visitors, so we can improve the site | Not personal data — the record cannot be linked to any identifiable person (GDPR Recital 26). Where an authority takes a different view, our basis is legitimate interests (Art. 6(1)(f)). |
3. Cookies
We use only necessary cookies (session login, shopping cart, CSRF protection, your currency choice and your cookie choice). We set no analytics cookies and no marketing cookies, and we use no third-party tracking scripts, pixels or social plug-ins. If we ever add any, we will ask for your consent first via the cookie banner. Details: Cookie Policy.
3a. Anonymous visit statistics
To understand how people find QiLuck, we keep a first-party, cookie-free count of visits on our own server. It is deliberately built so that it cannot identify you. Specifically:
| What is not stored | What is stored instead |
|---|---|
| Your IP address | Nothing. The IP is used in memory for a moment, then discarded. Only its one-way hash is used to de-duplicate a visit. |
| Your full user-agent (browser) string | Three coarse labels only: browser family, operating system family, device type (desktop / mobile / tablet). |
| Your name, email, account, or order history | Nothing. Visit statistics are never joined to your account. |
| Which pages you viewed, over time | Page counts per day in aggregate. The visit counter resets every calendar day and cannot be linked across days. |
| Any cookie or device identifier | Nothing. We write no cookie at all for statistics, so there is nothing to clear or block. |
Why this matters for your rights: because the record cannot be linked to an identifiable person, it is not "personal data" under the GDPR (Recital 26) and no consent banner is triggered by it. That also means we cannot single out one visitor's history — including yours. Raw visit detail is automatically deleted after 90 days; only anonymous daily totals are kept longer.
What we count: how many visits arrived from search, social, email or direct; which country a visit came from (country only, never a city or precise location); and four shop funnel steps in aggregate — product viewed, added to cart, checkout started, order completed. These are total counts, not per-person journeys.
Your choice is respected, and it is absolute. We honour Global Privacy Control (GPC) and Do Not Track (DNT): when your browser sends either signal, we record nothing at all for that visit — not even the anonymous counter. You can also opt out on this device at any time from the cookie banner; choosing "reject analytics" likewise stops all recording on this device. There is no "legitimate interest override" of your choice, and nothing about you is ever inferred from these numbers.
4. Retention (how long we keep things)
- Account data: kept while your account is active; deleted when you delete your account.
- Orders & invoices: up to 7 years (US/UK tax & accounting rules), decoupled from a deleted account. The delivery name, address and phone number are kept as part of the order record — we need them to handle a delivery problem, a return or a customs query long after the parcel arrives.
- Saved addresses: until you delete them. There is no tax or accounting reason to keep an address book, so deleting an address removes it immediately, and deleting your account removes all of them at once. Addresses already used on an order remain part of that order record (see above).
- Element profile / birth details / quiz answers: deleted immediately on account deletion or on request.
- Unsubscribe list: kept indefinitely (to honour your opt-out) with minimal data — email address only.
- Cookie consent log: 12 months.
- Anonymous visit statistics — raw detail: 90 days, then automatically and permanently deleted (see §3a).
- Anonymous visit statistics — daily totals: kept indefinitely. These contain no identifier of any kind, so there is nothing that could be traced back to you.
5. Who we share data with (processors)
- Email delivery — Brevo (transactional email: readings, gifts, receipts). Their infrastructure processes your email address to send our messages.
- Payments — our payment processor, PayPal (PayPal checkout). We never receive or store full card numbers. Payment data is handled by the processor under its own privacy policy, which also covers the fraud-screening checks it runs on a transaction.
- Delivery & customs — the postal or courier service that carries your parcel (for example your national postal service, DHL or another carrier). We pass them the recipient name, delivery address, phone number and a description of the contents, because they need these to deliver the parcel and to clear customs. Customs authorities may also require this information by law.
- Hosting & storage — our website host stores the application database.
We do not sell your personal data, and we do not share it for cross-context behavioural advertising.
6. International transfers
Our service providers may process data outside your country (including the US). Where required, transfers rely on the UK/EU International Data Transfer Agreement / Standard Contractual Clauses or an approved adequacy mechanism (e.g. EU–US Data Privacy Framework).
7. Your rights
UK / EU (GDPR & UK GDPR)
- Access & portability — download your data at Account → Download my data, or email us.
- Rectification — correct your data from your account pages or by email.
- Erasure — delete your account at Account → Delete my account (immediate cascade, see §8).
- Object / restrict — reach us at support@qiluck.com ; marketing opt-out via any email link or /unsubscribe.
- Withdraw consent — withdraw quiz/birth-data consent any time; we stop processing and delete the underlying data on request.
- Complain — you may complain to the UK ICO (ico.org.uk) or your local EU authority.
California (CCPA/CPRA) & other US states
- Right to know / access & delete — use the same account tools above, or email us. We verify via your account login.
- Right to correct — yes, same tools.
- Right to opt out of "sale"/"sharing" — we do not sell or share personal information as defined by the CCPA, so no opt-out signal is needed. If this ever changes, we will honour Global Privacy Control signals.
- Non-discrimination — exercising your rights never affects price or service quality.
We respond to verified requests within 30 days (GDPR: one month, extendable by two).
8. Account deletion — what is erased
Deleting your account immediately and permanently removes: your element profile and yearly snapshots, quiz answers, birth date/hour/time zone, reading unlocks, and account credentials. Orders are retained only as tax records, decoupled from your identity.
9. Children
QiLuck is not directed to children. You must be 18+ to create an account. We do not knowingly collect data from anyone under 18 (UK ICO Age Appropriate Design Code; US COPPA). If you believe a minor provided data, contact us and we will delete it.
10. Security
Passwords are stored only as salted scrypt hashes. Traffic is served over HTTPS. Access to production data is limited to authorised operators. No system is perfectly secure — we notify affected users and regulators of qualifying breaches as required by law (GDPR Art. 33/34; state breach-notification laws).
11. Changes to this policy
Material changes will be announced on the site (and by email where required). The version date at the top always reflects the current policy.
12. Contact
Privacy questions or requests: support@qiluck.com · Post: 中国浙江省义乌市稠江街道大路金小区