1. Introduction and scope
This Privacy Policy explains how Zelin Trading Co., Limited ("Zelin Trading", "we", "us" or "our") collects, uses, shares and protects personal information when you visit our website at zelinmy.com (the "Website"), contact us, or use our mobile management application published through the Google Play Store and the Apple App Store (the "App").
This Policy applies to the Website and the App together, and to our business operations described as: wholesale and retail of daily necessities, hardware products, household goods, electronic products, textiles and garments; import and export of goods and technology; business information consultation; supporting supply chain services; and general trade (excluding regulated businesses such as finance, insurance and lending).
Zelin Trading is the data controller for the personal information described in this Policy. Our service providers, including hosting providers, analytics providers and advertising technology partners, process information on our behalf as set out in section 5.
Your business counterparties, customers and suppliers may be individuals. Where you submit the personal information of another person (for example, a colleague on an order enquiry), you confirm that you have their permission to do so, and we will use that information only as described in this Policy.
2. Information we collect
2.1 Information you provide to us
- Account and profile information. When you create an account in the App or submit an enquiry through the Website, we collect your name, business email address, company name, role, country or region, and any credentials you choose to set.
- Enquiry and order information. The content of your enquiries and messages, purchase orders, product categories, quantities, destination details, delivery instructions and related correspondence.
- Commercial records. Quotations, invoices, payment status, credit terms and account history, retained to the extent required for accounting and tax purposes.
- Consulting materials. Where you engage our business information consultation, enterprise management advisory or project investment planning services, we collect the business information, market data and planning assumptions you or our advisors provide.
- Support content. Screenshots, diagnostic logs or files you send us when troubleshooting an order or an issue in the App.
2.2 Information collected automatically from your device
- Device information. Device model, operating system and version, app version, screen resolution, language and time zone settings, carrier and network type, and a device-generated identifier.
- Usage information. Pages visited, screens viewed, features used, search and filter selections, timestamps of actions, in-app events, session duration and approximate location derived from your IP address (for example, a city or region level).
- Advertising identifiers. The Apple Identifier for Advertisers (IDFA) and the Google Advertising ID (AAID / GAID), together with any other advertising or resettable device identifier available on your device.
- Log information. IP address, browser or device type, request timestamps, referring page, crash reports and diagnostic events used to keep the service secure and stable.
- Preferences. Your saved settings, language preference, notification preferences, and the categories, markets and suppliers you choose to follow in the App.
2.3 Optional location information
- Coarse location. Your App settings may allow you to share approximate location. We use it only if you enable the feature, and only to show region-specific stock information and to pre-fill delivery destinations.
- Precise location. We do not request precise GPS location. If your operating system prompts for precise location, declining it does not limit any feature of the App.
2.4 Information from third parties
- Advertising and measurement partners. Advertising networks and measurement providers may share aggregated performance data, impression counts, campaign attribution and the advertising identifier they have associated with your device.
- Trade counterparties. Where a customer or supplier's business record is legitimately shared with us as part of a transaction, we may receive limited related details.
- Store platforms. Apple and Google provide basic app usage and crash analytics, and may provide a privacy-preserving identifier associated with your account.
2.5 Information we do not collect
We do not knowingly collect sensitive personal data such as government identification numbers, payment card numbers (payment is handled by the store platform or a licensed payment processor), medical or biometric data, or information about your political opinions, religious beliefs or trade union membership. Please do not submit such information through the enquiry form.
3. How we use information
- To provide the service. To operate your account, fulfil enquiries and orders, display live inventory and order status, run the mobile management features, and deliver the business information consultation, enterprise management advisory, project investment planning and supporting supply chain services you have requested.
- To manage the trading relationship. To prepare quotations, process invoices, administer credit terms, handle returns and disputes, and maintain the commercial record of our dealings.
- To support and improve the App and Website. To diagnose errors, monitor performance, understand which features are used, fix defects, and develop new functionality across our eight business lines.
- To secure the service. To detect fraud and abuse, enforce our Terms of Service, and protect the security and integrity of our systems, our customers' data and our trade records.
- To personalise advertising. To deliver advertising within the App that is more relevant to you, where permitted and where you have not opted out, and to measure the performance of that advertising.
- To send service communications. Order confirmations, shipment updates, invoice notices, service announcements and responses to your enquiries. Marketing communications are sent only where permitted, and every message includes an unsubscribe control.
- To meet legal obligations. To comply with tax, accounting, customs and trade compliance, record-keeping and regulatory requirements, and to establish, exercise or defend legal claims.
- To act on your instructions. Including consent withdrawals, privacy choices and requests to delete or export your information.
4. Legal bases for processing
Where the GDPR or UK GDPR applies, we rely on the following legal bases. Where other regimes apply, the equivalent basis is noted.
| Jurisdiction / regime | Legal basis relied upon | Activities covered |
|---|---|---|
| EU — GDPR (Regulation (EU) 2016/679) | Performance of a contract (Art. 6(1)(b)) | Operating your account, processing orders and quotations, delivering the App features and trade services you request, and providing support. |
| EU — GDPR | Legitimate interests (Art. 6(1)(f)) | Security monitoring, fraud prevention, service analytics, maintaining business records, and improving the App and Website. We balance these against your rights and apply reasonable expectations. |
| EU — GDPR | Consent (Art. 6(1)(a)) | Advertising and analytics storage or access on your device, personalised advertising, and optional location features. You may withdraw consent at any time. |
| EU — GDPR | Legal obligation (Art. 6(1)(c)) | Tax, accounting, customs, export-control and record-keeping obligations. |
| UK — UK GDPR and Data Protection Act 2018 | Contract, legitimate interests, consent and legal obligation | As above, applied to users in the United Kingdom. The UK Addendum and the IDTA or UK Addendum to the SCCs govern restricted transfers. |
| EEA — ePrivacy Directive / national cookie law | Consent for non-essential cookies and similar technologies | Storing or reading information on your device, including advertising and analytics identifiers. |
| United States — California (CCPA / CPRA) and other state privacy statutes (for example Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Florida, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Kentucky and Rhode Island) | Contract performance; legitimate business purposes; opt-in consent for sale or sharing for cross-context behavioural advertising, with a right to opt out and limit use of sensitive personal information | Account and order fulfilment, service operation and security, and advertising measurement. Where a state law grants the right to opt out of sale or sharing, we honour it as described in section 12. |
| Brazil — LGPD (Lei Geral de Proteção de Dados, Lei No. 13.709/2018) | Consent; contract performance; legitimate interest; compliance with legal or regulatory obligation | Processing carried out in Brazil or affecting individuals in Brazil. Rights of confirmation, access, correction, anonymisation, blocking, deletion, portability and information about sharing are honoured. |
| Canada — PIPEDA (and provincial equivalents such as Alberta PIPA and Quebec Law 25) | Implied consent for necessary purposes; express consent for non-essential uses; contract performance; reasonable security safeguards | Commercial activity with individuals in Canada. In Quebec, the additional requirements of Law 25 apply, including the right to request review of automated decisions. |
| Australia — Privacy Act 1988 and Australian Privacy Principles | Consent; contract performance and necessity; compliance with legal obligation; permitted general situations | APP 1 to APP 6 compliance, including the Australian Privacy Principles, privacy notices, access and correction rights, and the notifiable data breaches regime. |
| Singapore — PDPA | Consent; contract performance; legitimate interests assessed against the Legitimate Interests Assessment test; legal obligation | Collection, use, disclosure and retention of personal data in Singapore, together with the data breach notification and data portability obligations. |
| India — Digital Personal Data Protection Act 2023 and the Digital Personal Data Protection Rules | Consent (notice and consent, or consent for certain legitimate uses); contract performance; compliance with legal obligation | Processing of digital personal data in India. Data fiduciary obligations, security safeguards, grievance redressal and cross-border transfer restrictions are observed. |
| Japan — APPI (Act on the Protection of Personal Information) | Consent; contract performance; legally mandated permitted uses | Handling of personal information in Japan, including the cross-border transfer notice requirement and the rights to request disclosure, correction and cessation of use. |
| South Korea — PIPA (Personal Information Protection Act) | Consent; contract performance; compliance with statutory obligations | Processing in Korea, including the rights to request access, correction, deletion and suspension, and consent withdrawal for marketing and overseas transfer. |
| Other major regions — for example EEA member states not separately listed, Hong Kong (PDPO), Mainland China (PIPL), Thailand (PDPA), the Philippines (Data Privacy Act), Malaysia (PDPA) and New Zealand (Privacy Act 2020) | The equivalent basis recognised under the applicable regime | We apply the same core principles: purpose limitation, minimisation, transparency, security safeguards, and rights of access, correction, deletion and objection. |
5. Sharing and processors
We do not sell your personal information for cash. We share information only with the categories of recipients below, and only to the extent needed for the stated purpose. Where a recipient acts on our behalf, we put a written data processing agreement in place.
- Service providers and processors. Cloud hosting and content delivery providers, database and application service providers, email and messaging providers, customer support tooling, analytics providers, error monitoring services and payment processors.
- Advertising technology partners. The App integrates third-party advertising SDKs, as detailed in section 9, which act as processors or as independent controllers depending on the specific interaction.
- Store platforms. Apple App Store and Google Play, which distribute the App and provide services such as in-app purchase processing, receipt validation and mandatory privacy disclosures.
- Trade and logistics partners. Freight forwarders, customs brokers, warehouses, inspection providers and payment intermediaries, but only to the extent required to deliver, inspect or settle a specific shipment you have ordered.
- Professional advisers and auditors. Legal, accounting, tax and audit advisers, and insurers, under confidentiality obligations.
- Authorities. Customs, tax, regulatory, law enforcement or court bodies where disclosure is required or permitted by law, or to establish, exercise or defend legal claims.
- Corporate transactions. Buyers and transferees in a merger, reorganisation or sale of assets, subject to confidentiality and to this Policy continuing to apply.
We do not disclose personal information to third parties for their own independent marketing purposes without a separate notice and, where required, consent.
6. International transfers
Zelin Trading is established in Hong Kong and our service providers operate globally. As a result, personal information collected in one jurisdiction may be processed in another, including Hong Kong, the European Economic Area, the United Kingdom, the United States, Singapore, India and Australia.
Where personal information is transferred outside the jurisdiction where it was collected, we rely on an appropriate transfer mechanism, which may include: Standard Contractual Clauses approved by the European Commission, the UK International Data Transfer Addendum to the EU SCCs, the Personal Information Protection Commission of Japan / APPI recognition, or another mechanism recognised under the applicable regime. Where required by law we obtain the data subject's consent, and we apply supplementary measures such as encryption in transit and at rest, access controls and transfer impact assessments.
You may contact us using the details in section 17 to request information about the safeguards applicable to a transfer from your jurisdiction.
7. Retention periods
We keep personal information only for as long as we need it for the purposes described in this Policy, and no longer than the relevant legal or business requirement allows.
| Category of information | Typical retention period | Reason for the period |
|---|---|---|
| Account and profile information | For the life of the account, plus 24 months after closure | Provision of the service, support, and defence against claims. |
| Enquiry and correspondence records | 3 years from last contact | Commercial relationship management and legal defence. |
| Orders, invoices and customs documentation | 7 years from the transaction date | Tax, accounting and customs record-keeping obligations. |
| Consulting and investment planning materials | 5 years from delivery | Professional record-keeping and dispute resolution. |
| Raw device and usage logs | Up to 24 months, aggregated after 6 months | Security monitoring, diagnostics and service improvement. |
| Advertising identifiers and consent records | Until you withdraw consent, reset your identifier, or 13 months of inactivity | Consent management, opt-out enforcement and frequency capping. |
| Server access and security logs | 12 months | Investigation of security incidents and abuse. |
| Backups | Rolling 35-day cycle | Disaster recovery and service continuity. |
8. Security
We apply technical and organisational measures proportionate to the nature of the information we hold, including:
- TLS encryption for data in transit across the Website, the App and all administrative systems.
- Encryption at rest for databases and backups, with managed key rotation.
- Role-based access control, least-privilege permissions and multi-factor authentication for all staff access to customer data.
- Environment separation between development, staging and production, with production access granted on a need-to-know basis.
- Centralised logging and monitoring of access to personal data, with regular review.
- Secure software development practices, dependency scanning and vulnerability patching on a defined schedule.
- Periodic independent penetration testing and risk assessments of our systems and processes.
- Vendor due diligence and written contractual obligations for every processor that handles personal data on our behalf.
- Staff training on data protection, with confidentiality obligations in employment contracts.
No system is perfectly secure. If we become aware of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within the period required by applicable law (for example, 72 hours under the GDPR), and notify affected individuals where the threshold is met. Where a breach affects users in Australia, Singapore, Brazil, Japan, Korea, Canada, India or the United States, we will make the notifications required by those regimes.
9. Advertising and monetisation
The Zelin Trading mobile management application is supported by advertising. We integrate third-party advertising SDKs that may collect information from your device in order to serve and measure advertising. These partners operate their own privacy policies and, in many cases, their own consent frameworks. We configure each SDK to respect the consent signals and privacy choices you make.
The table below lists the advertising platforms we integrate with, the purpose of each integration, and the route to opt out. Opting out of one partner does not opt you out of the others; where your jurisdiction provides a global signal (for example the Global Privacy Control, or the IAB Europe TCF string) we treat that signal as applying to all of them.
| Advertising platform | Purpose of the integration | Opt-out / preference route |
|---|---|---|
| Google AdMob | App banner, interstitial, rewarded and app open ads; mediation and revenue reporting. | My Ad Center (ads.google.com/myadcenter) and in-app "Ad Settings". |
| Google Ad Manager | Publisher-side ad serving and campaign delivery management for promoted placements. | Google Ads Settings (adssettings.google.com) and Google My Ad Center. |
| Meta Audience Network | Banner, interstitial, native and rewarded video placements. | Meta Business Help Center (facebook.com/business/help) and Meta's Privacy Checkup. |
| Unity Ads | In-app video and rewarded video advertising across our media surfaces. | Unity Privacy Preference Center (unity.com/legal/privacy-choices). |
| AppLovin | Mediated in-app video and banner advertising, plus campaign measurement. | AppLovin Privacy Center (applovin.com/privacy) and in-app ad settings. |
| ironSource (LevelPlay) | Mediation layer for bidding, waterfalling and revenue optimisation across ad formats. | ironSource Privacy Centre (ironsource.com/privacy) and device-level "Limit Ad Tracking". |
| Vungle / Liftoff | Rewarded video and interstitial video advertising with monetisation reporting. | Liftoff Privacy Preference Center and Vungle consent controls. |
| Pangle (TikTok for Business) | App open, interstitial and rewarded video advertising placements. | TikTok Privacy Center (tiktok.com/privacy) and in-app ad settings. |
| Mintegral | Rewarded video and banner advertising with campaign performance measurement. | Mintegral Privacy Policy and device-level advertising identifier reset. |
| Chartboost | Rewarded video, interstitial and banner advertising; attribution reporting. | Chartboost Privacy Ad Services (chartboost.com/legal/privacy) and in-app opt-out. |
| AdColony (Digital Turbine) | Video advertising placements and engagement measurement. | Digital Turbine Privacy Policy and in-app ad settings. |
| InMobi | Advertising mediation, audience segments and campaign measurement across formats. | InMobi Privacy Preference Center (inmobi.com/legal/privacy) and device-level opt-out. |
| Amazon Ads | Advertising and conversion measurement for promoted marketplace placements. | Amazon Ads Privacy Options (amazon.com/ads/privacy) and your Amazon advertising preferences. |
| Digital Turbine | App monetisation and advertising performance analytics. | Digital Turbine Privacy Policy and in-app consent settings. |
| Smaato | Mediated banner, interstitial and rewarded video advertising. | Smaato Privacy Centre (smaato.com/privacy) and app-level ad controls. |
| Fyber | Rewarded video and marketplace monetisation for media surfaces. | Fyber Privacy Policy and the consent platform presented in the App. |
| Ogury | Permission-based audience building and advertising measurement. | Ogury Privacy Centre (ogury.com/privacy) and in-app consent withdrawal. |
| Criteo | Retargeting, lookalike audience campaigns and commerce advertising measurement. | Criteo Privacy Center (criteo.com/privacy) and in-app advertising choices. |
| Teads | Native and video advertising placements with campaign measurement. | Teads Privacy Hub (teads.com/privacy) and device-level advertising limits. |
| Moloco | Machine-learning based ad auction and campaign optimisation. | Moloco Privacy Policy and app-level consent settings. |
| PubMatic | Programmatic header bidding, yield optimisation and campaign delivery reporting. | PubMatic Privacy Centre (pubmatic.com/privacy) and in-app ad settings. |
| Magnite | Supply-side platform functions, advertising auction and yield management. | Magnite Privacy Policy and the privacy controls presented within the App. |
9.1 Personalised and non-personalised advertising
- Personalised advertising. Where you have consented (or where the law permits use without consent), we may use information such as your advertising identifier, app activity, device type, approximate location and content interactions to select advertising for you. Personalised advertising is not shown to users we know to be under the applicable age threshold, and is not shown where you have opted out.
- Non-personalised (contextual) advertising. Where consent is not required, we limit advertising selection to the content of the screen you are viewing, your approximate country or region, the language of the App and your device type. No behavioural profile is used to select those ads.
9.2 GDPR, CCPA and consent management
- In the European Economic Area, the United Kingdom and other consent-required regions, we present a consent platform before non-essential advertising is served. You may accept, reject or manage purposes individually. Rejecting consent does not limit your access to the App or its core features.
- In California and other US states with opt-out rights, you may opt out of the sale or sharing of personal information for cross-context behavioural advertising. We honour a valid Global Privacy Control signal as an opt-out request for sale or sharing.
- Where you have withdrawn consent, we instruct our advertising partners to stop using the identifiers collected on the basis of consent, and we delete the associated consent record.
9.3 Apple App Tracking Transparency and advertising identifiers
- On Apple devices running iOS 14 or later, the App presents the App Tracking Transparency prompt where tracking would otherwise occur. If you decline, we do not track you across apps and websites owned by other companies, and you receive contextual advertising only.
- We request the IDFA only after you grant permission through the ATT prompt, and only where needed for advertising attribution.
- We use the AAID (Google Advertising ID) only where it is permitted, we respect the device-level "Limit Ad Tracking" and "Delete" controls, and we reset identifiers when you ask us to.
10. Advertising formats and user controls
The App displays the following advertising formats. Each format is clearly distinguishable from application content, and none of them is presented as a feature of the trading service.
| Format | What it is | Your controls |
|---|---|---|
| App open ads | A full-screen advertisement displayed when you open the App. | Can be disabled in App settings; is not served to users in the applicable under-age threshold. |
| Rewarded video ads | A video ad that grants an in-app benefit, such as a bonus on a business information consultation summary, once it has been viewed to completion. | Optional; no trading, order or inventory function is blocked if you decline. |
| Interstitial ads | A full-screen ad shown at a natural transition point between screens. | Dismissible, with a visible close control; frequency is limited and configurable in App settings. |
| Banner ads | A small static or animated advertisement placed within a content area. | Removable through the "Remove ads" purchase where available, and controllable via your device's advertising settings. |
Additional user controls are available from the App's settings screen: an "Advertising" section with a switch to limit personalised advertising, a link to open the consent platform again and change your choices, and a control to reset or delete your advertising identifier. On iOS you can also use Settings › Privacy & Security › Tracking to reset or limit identifier use; on Android you can use Settings › Privacy › Ads to delete or reset the Google Advertising ID and opt out of personalisation.
11. Cookies and similar technologies
The Website uses cookies and similar technologies. Because our Website is operated as a single-page-style corporate site, we keep this list deliberately short and free of advertising cookies.
| Technology | Purpose | Type |
|---|---|---|
| Strictly necessary cookies | Session integrity, security, load balancing and remembering privacy choices such as your consent decision. These cannot be switched off. | Essential |
| Functional preferences | Remembering interface settings and your last selected market or category. | Functional |
| Analytics | Aggregate measurement of page views and navigation patterns, used only where permitted and, in consent-required regions, only after consent. | Analytics |
| Local storage / app preferences | Storing non-sensitive interface state on your device so the App loads quickly. Clearing the App's storage removes these values. | Essential / functional |
Where consent is required, a consent banner appears when you first visit the Website. You can change your choice at any time through the "Privacy choices" link in the footer of every page. Disabling analytics and advertising technologies does not affect your ability to browse our services or place an enquiry.
12. Your rights by region
Subject to the regime that applies to you, you may have the following rights. Where a right is subject to exemptions — for example the right to erasure does not apply where retention is required for tax or customs record-keeping — we will explain the reason for the limit.
| Region | Main rights available to you | How to exercise them |
|---|---|---|
| European Union / European Economic Area and United Kingdom | Access, rectification, erasure, restriction of processing, data portability, objection (including objection to direct marketing and to processing based on legitimate interests), and withdrawal of consent at any time. | Email support@zelinmy.com with "Data rights request" in the subject line. We respond within one month, extendable by two further months for complex requests, and will tell you if we need identity verification. |
| United States — California | Know categories of personal information collected, sources, purposes and third parties; request deletion; request correction; opt out of sale or sharing for cross-context behavioural advertising; limit use of sensitive personal information; non-discrimination for exercising rights. | Email support@zelinmy.com, or use the "Do Not Sell or Share My Personal Information" link where presented. We confirm receipt within 48 hours and act within 45 days, extendable by 45 days with notice. |
| United States — other state privacy laws (for example Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, Florida, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Kentucky, Rhode Island) | Access, correction, deletion, portability, opt out of profiling and targeted advertising, opt out of sale of sensitive data, universal opt-out mechanism recognition, and limit use of sensitive data. | Email support@zelinmy.com. We honour valid opt-out preference signals such as the Global Privacy Control where required. |
| Brazil | Confirmation of processing, access, correction, anonymisation, blocking or deletion of unlawful data, portability, information about sharing, withdrawal of consent, and review of decisions made solely by automated processing. | Email support@zelinmy.com. Requests may be raised in Portuguese and are answered in the language in which they are made. |
| Canada | Access and correction of personal information, and in Quebec, additional rights including review of automated decisions and withdraw from the sale of personal information. | Email support@zelinmy.com or ask any member of our Hong Kong team for the privacy officer. |
| Australia | Access and correction, consent withdrawal, and the right to complain to the Office of the Australian Information Commissioner. | Email support@zelinmy.com. We will not charge you for a request and will not treat you adversely for making one. |
| Singapore | Withdrawal of consent, correction of inaccurate data, and protection against the collection, use and disclosure of personal data that is inconsistent with the PDPA. | Email support@zelinmy.com. We will respond within the period required by PDPA and explain any request we cannot meet. |
| Japan | Request of disclosure, correction and cessation of use, and the right to be informed about the handling of personal data including overseas transfers. | Email support@zelinmy.com. Requests are handled under the APPI disclosure and correction procedure. |
| South Korea | Access, correction, deletion, suspension of processing, withdrawal of consent including for marketing and cross-border transfer, and rights arising from automated decisions. | Email support@zelinmy.com. We comply with the obligations of the Personal Information Protection Commission. |
| India | Access to information, correction and erasure, grievance redressal, nomination, and information about the manner and extent of processing and sharing. | Email support@zelinmy.com. We maintain a grievance redressal process and acknowledge requests promptly. |
| Other regions | Wherever local law grants a right, we apply the same core principle: you can ask what we hold, ask us to correct or delete it, ask us to stop a particular use, and complain if you are not satisfied. | Email support@zelinmy.com with the subject line "Privacy request". We aim to respond within one business day in every case. |
How to exercise a right: email support@zelinmy.com. Please include "Privacy request" in the subject line and tell us which right you wish to exercise. For key account matters you may also write to aiyangping@zelinmy.com. We do not charge a fee for a request, we will not discriminate against you for making one, and we will verify your identity only to the extent necessary to act on your request.
13. Children's privacy and age policy
The Website and the App are business services intended for adults. They are not directed at children, and we do not knowingly collect personal information from anyone under the age of 13, or under 16 where a higher threshold applies under local law.
- COPPA (United States). We do not knowingly collect personal information from children under 13. If you believe a child has provided us with personal information, contact us and we will delete it promptly.
- GDPR-K and equivalent children's rules. Where the legal basis for processing relies on consent and the individual is below the age of majority for consent in their jurisdiction, a parent or guardian must give consent. Our business services are not intended for children, so we do not knowingly seek that consent.
- App store age ratings. The App is rated for a general audience and for ages 13 and over. We configure our advertising SDKs so that personalised advertising is not served to users known to be under the applicable threshold, and we disable data collection for known child-directed configurations where the platform provides the signal.
- Verified age checks. Where a store platform or an advertising partner signals child-directed content, we disable behavioural advertising and restrict the collection of identifiers for that session.
14. App store compliance
14.1 Apple App Store Review Guidelines
The App is submitted for review and continues to be distributed in accordance with the Apple App Store Review Guidelines. We provide a privacy policy in the App and in App Store Connect, complete the App Privacy Details questionnaire, and limit data collection to what the advertised functionality requires. We do not collect data for purposes that would require separate permission under the guidelines.
14.2 Google Play Data Safety section
We complete and maintain the Google Play Data Safety form. The declarations made there reflect the actual data practices described in this Policy, including data types collected, whether the data is shared, whether collection is optional, whether the data is encrypted in transit, and the mechanism available for requesting data deletion. If our practices change, the Data Safety form is updated before the change is released.
14.3 Google Play Families policy and the Apple kids category
The App is not directed at children and is not listed in the Google Play "Designed for Families" category or the Apple Kids Category. We nonetheless comply with the Families policy requirements applicable to the advertising SDKs we integrate, including the requirement to use self-certified SDKs and to configure child-directed treatment for known child-directed placements. We do not permit behavioural advertising or the collection of identifiers in any child-directed configuration.
15. Do Not Track and Global Privacy Control
The Website does not respond to the legacy "Do Not Track" browser signal, because there is no widely adopted industry standard for interpreting it and because honouring it inconsistently would create a false impression of the protections you have.
We do honour the Global Privacy Control (GPC) signal where it is recognised by law, including in California and other US states that require universal opt-out mechanism recognition. Where a valid GPC signal is detected, we treat it as a request to opt out of the sale or sharing of personal information for cross-context behavioural advertising, and we apply it across all advertising partners listed in section 9. Where a consent platform is presented, we do not serve non-essential advertising where the signal indicates refusal.
16. Changes to this policy
We may update this Privacy Policy from time to time to reflect changes in our services, our legal obligations or our partners. Where a change is material — for example a new category of data we collect, a new advertising partner, or a new processing purpose — we will provide a clear notice through the App, the Website or by email to affected users, and where the law requires it we will obtain consent before the change takes effect.
We will record the effective date at the top of this Policy and retain previous versions on request. Continuing to use the Website or the App after an update means the updated Policy applies from its stated effective date.
17. How to contact us
If you have any question about this Policy, about our use of your personal information, or about a privacy request, contact us:
- Business support: support@zelinmy.com
- Key accounts: aiyangping@zelinmy.com
- Company: Zelin Trading Co., Limited
- Office: RM 701, UNIT 108, 7/F, TWR B NEW MANDARIN PLAZA, 14 SCIENCE MUSEUM RD, TSIM SHA TSUI, HONG KONG
- Website: zelinmy.com
You may also ask us to direct your request to our data protection contact. If you are unsatisfied with our response, you have the right to complain to your local supervisory authority — for example the Information Commissioner's Office in the United Kingdom, the CNIL or a relevant Data Protection Authority in the European Union, the Attorney General's office for privacy complaints in California, the Office of the Australian Information Commissioner, or the Personal Data Protection Commission in Singapore.
18. Effective date
Effective date: 21 September 2026. This Policy was last updated on 21 September 2026 and replaces any earlier version published on the Website or distributed through the App.