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)

DataPurposeLawful basis (GDPR)
Email, display name, password hashAccount, orders, order emailsContract (Art. 6(1)(b))
Quiz answers & resulting elementYour element profile & recommendationsConsent (Art. 6(1)(a)) — quiz consent checkbox
Birth date, hour, time zone (optional, birth-mode only)Generate your BaZi-based readingExplicit consent (Art. 9 conditions / Art. 6(1)(a)) — separate checkbox
Orders & purchases (items, amounts, status)Fulfilment, receipts, refunds, tax & dispute recordsContract + legal obligation (Art. 6(1)(b)/(c))
Shipping address (physical items only)DeliveryContract
Delivery phone number (physical items only)Carrier contact for delivery and customs clearance; notifying you of a delivery problemContract (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have to re-type them; you can add, edit or delete them at any time in My Account → My addressesConsent (Art. 6(1)(a)) — withdrawn by deleting the address
Email engagement (unsubscribes, send logs)Honour opt-outs; CAN-SPAM / PECR complianceLegal obligation / legitimate interests
Cookie consent record (category, timestamp)Proof of consent (ePrivacy)Legal obligation
Security & server logs (hashed UA fingerprint)Abuse prevention, securityLegitimate 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 siteNot 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 storedWhat is stored instead
Your IP addressNothing. 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) stringThree coarse labels only: browser family, operating system family, device type (desktop / mobile / tablet).
Your name, email, account, or order historyNothing. Visit statistics are never joined to your account.
Which pages you viewed, over timePage counts per day in aggregate. The visit counter resets every calendar day and cannot be linked across days.
Any cookie or device identifierNothing. 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)

5. Who we share data with (processors)

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)

California (CCPA/CPRA) & other US states

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