Lingxia Privacy Policy
Introduction
“Lingxia” (hereinafter referred to as “Lingxia” or “we”) understands the importance of personal information to you and will make every effort to protect the security of your personal information. In accordance with the Cybersecurity Law of the People’s Republic of China, the Data Security Law of the People’s Republic of China, the Personal Information Protection Law of the People’s Republic of China, the Information Security Technology - Personal Information Security Specification, and other relevant laws, regulations, and technical standards, we have formulated this Privacy Policy (the “Policy”) to explain how we collect, use, store, share, and protect your personal information, as well as the rights you have with respect to your personal information.
This Policy applies to all scenarios in which you download, install, launch, register for, log in to, and use the Lingxia iOS application (App) (collectively, “using our products and/or services”). Terms that may have a significant relationship with your rights and interests, and terms involving the processing of sensitive personal information, are marked in bold. Please read them carefully.
Important notice: Lingxia is a lightweight product combining traditional cultural knowledge, AI interaction, and entertainment-oriented communication. Palmistry, facial analysis, and other interpretation results provided by us are generated based on traditional cultural classics and AI models, are for your personal research, entertainment reference, and life inspiration only, and do not constitute or replace any professional legal, medical, financial, or psychological advice.
Please carefully read and fully understand this Policy before using or continuing to use our products and services, and make appropriate choices according to this Policy when needed. If you do not agree to this Policy, our products and/or services may not operate normally, and you should stop accessing or using the relevant functions. Your act of checking consent or continuing to use the products and/or services we provide means that you fully understand and agree to all contents of this Policy, including updated versions.
About Us
The operator of Lingxia products and services, and the personal information processor, is FORTUNETELL AI LIMITED (the “Operator,” “we,” or “us”).
Registered address: UNIT 1801, 18/F, 382 LOCKHART ROAD, WAN CHAI, HONG KONG.
If you have any questions, comments, or complaints about this Policy or personal information protection matters, you may contact us through the methods listed in the “How to Contact Us” section of this Policy.
Table of Contents
1. How We Collect and Use Your Personal Information
2. How We Share, Transfer, and Publicly Disclose Your Personal Information
3. How We Store and Protect Your Personal Information
4. How You Manage Your Personal Information
5. How You Cancel Your Account
6. How We Use Local Cache and Similar Technologies
7. Protection of Minors
8. How We Update the Privacy Policy
9. How to Contact Us
10. Miscellaneous
1. How We Collect and Use Your Personal Information
We follow the principles of legality, legitimacy, necessity, and good faith. For the purposes described in this Policy, we collect and use personal information that you actively provide or that is generated when you use our products and/or services. If we need to use your personal information for purposes not stated in this Policy, or use collected information for other purposes, we will inform you again in a reasonable manner and obtain your consent.
(1) Account Registration and Login
When you register for or log in to a Lingxia account, we collect your mobile phone number to complete registration, login, and account recovery through SMS verification codes, create your account, and protect account security. A mobile phone number is sensitive personal information, but it is necessary for registration and login functions.
Before you use functions that legally require real-name authentication, such as publishing or commenting, we may complete real-name verification based on the mobile phone number you registered, in accordance with network real-name requirements.
You may also choose to fill in or modify your nickname, avatar, gender, and date of birth to improve your profile. If you do not provide such information, it will not affect your use of the basic functions of the product. If you successfully register, we will display your nickname, avatar, and the profile information you choose to make public in the product.
(2) Providing Core Products and Services
1. Image analysis functions, including palmistry and facial analysis. When you use image analysis functions such as palmistry or facial analysis, you may take a photo with the camera or select an image from your album and upload it. We upload the image to the server for AI analysis and return the analysis result to you. The collection and processing method for this image is the same as for other images you upload. We use it only to generate the current analysis result for you, not to identify or verify your identity, and not for any other purpose not stated in this Policy. Please exercise your own judgment before uploading images containing faces or similar information. Images uploaded for analysis are deleted from the server after analysis is complete and are not retained long term. If you actively choose to save the result, the relevant result will be stored in encrypted form and may be deleted by you at any time.
2. File upload and analysis functions. When you upload images, PDFs, Word (docx) files, or other files for analysis or communication, we read the corresponding local files and upload them to the server for processing in order to return analysis or communication results to you. Please confirm the file content before uploading and avoid uploading unnecessary personal information or sensitive information of others.
3. Interactive communication and voice message functions. When you send text, images, or voice messages during interactive communication, we collect and store the corresponding content you send. When sending a voice message, we call the microphone to record audio during your operation. Such content is stored on our servers to implement message sending, receiving, and display functions, is stored in encrypted form, and may be deleted by you at any time.
4. Information browsing, publishing, liking, favoriting, sharing, and related functions. To display content to you and implement interactive functions, we collect your browsing records and click operation records, including follows, browsing, searches, likes, favorites, shares, comments, publishing records, and related behaviors. Your browsing records and click operation records are sensitive personal information, but they are necessary for content display and publishing services. Text, images, voice, comments, favorites, shares, and other information you publish will be stored on our servers in encrypted form and may be deleted by you at any time.
5. Search function. When you use search, we collect the keywords you query, access time, and relevant interaction records to return the content you need and improve our products and services.
6. Customer service and after-sales functions. When you contact customer service or submit an after-sales request, we may need you to provide relevant information consistent with prior information to verify your identity and resolve the issue, and we may collect communication records between you and us, including account information, images/videos/text provided to prove relevant facts, contact information, and online communication or telephone recording records. We may also actively communicate with you by telephone, SMS, in-app messages, or other means regarding issues arising during use.
(3) Ensuring Safe Operation of Products and Services
To ensure the safe and stable operation of software and services, prevent fraud, and protect account security, we collect your device information, including device/hardware model, device name, operating system and version, application version, language settings, device identifiers such as IDFV, network-related information such as IP address, network access method and network quality data, device sensor data, application crash and operation logs, and use such information for security risk-control verification. We will keep the frequency of reading device identifiers within a reasonable range. We do not read the advertising identifier (IDFA) and do not track you across apps or websites.
If this product needs to receive push notifications while closed or in the background, the corresponding capability may be required to receive push messages. This is necessary to implement the push function. Without your consent, we will not perform unrelated associated launches.
(4) Device Permission Calls
We may call your device permissions while providing services. They are summarized below. You may enable or disable some or all permissions in your device Settings. Different devices may display and disable permissions differently; please refer to your device and operating system instructions. On iOS devices, permissions such as camera, microphone, album/photos, and notifications will be separately requested through system pop-ups when you first use the corresponding function, and you may change them at any time in system Settings.
| Device Permission | Business Function | Function Scenario | Can It Be Disabled |
|---|---|---|---|
| Network permission | Core business functions | App content reading and updates, AI interaction result return, and user-uploaded content transmission | Yes. After disabling it, App content cannot be read or updated in real time, and the App cannot be used normally. |
| Album and storage permission | 1. Stable App operation; 2. Upload images/files; 3. Save content | 1. Log recording and information cache; 2. Reading album and local storage content when uploading avatars, palmistry/facial images, PDFs, Word files, or other files; 3. Saving AI analysis results or images locally | Yes. Disabling it only affects the corresponding functions and does not affect other App functions. |
| Camera permission | Taking palmistry/facial images and uploading images | When you use palmistry or facial analysis, the camera is called to take photos in real time for AI entertainment-oriented analysis, or to take images for upload. | Yes. Disabling it only affects the corresponding functions and does not affect other App functions. |
| Microphone permission | Voice sending function | When you send voice messages during interactive communication, the microphone is called for recording. | Yes. Disabling it only affects the corresponding functions and does not affect other App functions. |
| File reading permission | File upload function | When you upload images, PDFs, Word (docx) files, or other files to the App for analysis or communication, local files are read. | Yes. Disabling it only affects the corresponding functions and does not affect other App functions. |
| Notification permission | System notifications | App-related message pushes, such as AI analysis completion reminders, system announcements, and interaction messages | Yes. Disabling it only affects the corresponding functions and does not affect other App functions. |
Please note: Lingxia does not collect your precise or approximate geographic location information, nor does it read your contacts or SMS content. We collect only necessary information directly related to the above functions and do not collect personal information unrelated to the services provided.
(5) Exceptions to Authorization and Consent
According to relevant laws and regulations, we do not need to separately obtain your consent to collect and use your personal information in the following circumstances:
- Where necessary to enter into or perform a contract to which you are a party;
- Where necessary to perform statutory duties or obligations;
- Where necessary to respond to a public health emergency, or to protect the life, health, and property safety of natural persons in an emergency;
- Where personal information is processed within a reasonable scope for public interest news reporting, public opinion supervision, or similar activities;
- Where your self-disclosed personal information or other legally disclosed personal information is processed within a reasonable scope according to law;
- Where necessary to maintain the safe and stable operation of products and/or services, such as detecting and handling failures of products or services;
- Other circumstances provided by laws and administrative regulations.
2. How We Share, Transfer, and Publicly Disclose Your Personal Information
(1) Sharing
We do not share your personal information with any company, organization, or individual, except in any of the following circumstances:
- Your consent or separate consent has been obtained in advance;
- You request it yourself;
- It falls under the statutory circumstances described in item (4) of this section.
Lingxia’s core functions, including account login, content storage, AI analysis of images and files, and interactive communication, are implemented and operated by us independently. We have not integrated third-party SDKs and will not provide your personal information to third parties for their own purposes. If we need to introduce a third party to process your personal information in the future, we will update this Policy in advance, list the relevant third-party information, and obtain your consent.
(2) Transfer
Unless we obtain your explicit consent, we will not transfer your personal information to any company, organization, or individual, except in the following circumstances: (1) your consent has been obtained in advance; (2) you request it yourself; (3) if a merger, division, acquisition, bankruptcy liquidation, or similar event occurs and personal information transfer may be involved, we will inform you of the relevant situation and require the new holder to continue to be bound by this Policy, otherwise we will require it to obtain your consent again; (4) other circumstances provided by laws and regulations.
(3) Public Disclosure
In principle, we do not publicly disclose your personal information. If public disclosure is truly necessary, such as publishing violation handling notices or cooperating with regulatory requirements according to law, we will proceed according to law and display only necessary desensitized information after obtaining your express consent or under statutory circumstances.
(4) Consent Exceptions for Sharing, Transfer, and Public Disclosure
According to relevant laws and regulations, we may process your personal information without obtaining your prior authorization or consent in circumstances such as fulfilling statutory obligations, matters directly related to national security or public interests, matters directly related to criminal investigation, protecting major lawful rights and interests of you or others where it is difficult to obtain your consent, or where you have disclosed the information yourself or it has otherwise been lawfully disclosed. Sharing or transferring de-identified information where the recipient cannot re-identify a specific individual does not require separate notice or consent.
3. How We Store and Protect Your Personal Information
(1) Storage Location
Personal information collected and generated during our operations within the territory of the People’s Republic of China is stored within the territory of the People’s Republic of China. If cross-border provision is truly necessary, we will perform corresponding legal obligations, such as separately informing you through in-app notice or email, obtaining your separate consent, conducting an outbound security assessment, or entering into a standard contract, before doing so.
(2) Storage Period
We retain your personal information only for the shortest period necessary to achieve the processing purposes described in this Policy, and comply with mandatory legal and regulatory retention requirements. Images you upload for analysis are deleted immediately after analysis is complete. After the retention period expires, we will delete or anonymize your personal information. If we stop operations, we will promptly stop collection, notify you individually or by announcement, and delete or anonymize the personal information we hold.
(3) Security Protection Measures
We adopt industry-standard technical and management measures to protect your personal information, including encrypted data transmission and storage, access permission control, data classification and grading, secure development standards, and regular security audits, to reduce the risk of information being damaged, misused, leaked, accessed without authorization, or altered. Please properly safeguard your account and password. The internet environment is not absolutely secure. If a personal information security incident unfortunately occurs, we will initiate an emergency plan as required by laws and regulations, promptly inform you of the incident and response measures by email, SMS, in-app message, push notification, announcement, or other means, and report to regulatory authorities as required.
4. How You Manage Your Personal Information
We value and protect your rights regarding personal information. You may exercise your rights in the following ways:
- Access, copy, correct, and supplement: You may access, copy, and correct your avatar, nickname, gender, birthday, and other profile information through [Me - Edit Profile], and access or correct your mobile phone number, login password, and other account information through [Me - Account and Security].
- Deletion: You may delete content you publish, uploaded images/files, interactions, and browsing records at any time. Where statutory circumstances apply, you may also request that we delete corresponding personal information.
- Change or withdraw authorization: You may change or withdraw authorization for camera, microphone, album, notification, and other permissions through the device operating system settings. After withdrawal, we will no longer collect the corresponding information, but related functions may become unavailable. Withdrawal does not affect processing previously carried out based on authorization.
- Copy and transfer: Where conditions prescribed by national cyberspace authorities are met, you may request that personal information be transferred to the personal information processor you designate.
- Request explanations for automated decision-making: Lingxia’s AI analysis is automated processing. Results are for entertainment reference only and will not make decisions that have legal effect or significant impact on you. If you believe an automated decision significantly affects your lawful rights and interests, you have the right to request an explanation from us, and we will provide appropriate remedies.
- Complaints and contact: If you cannot operate by yourself due to security or identity verification reasons, or wish to further exercise the above rights, you may contact us through the methods listed in Section 9. We will respond within fifteen working days after verifying your identity.
5. How You Cancel Your Account
You may initiate account cancellation in the App through [Me - Account and Security - Cancel Account] and select [Apply to Cancel Account] when the cancellation conditions are met. You may also submit an account cancellation or data deletion request through the contact methods in Section 9. After account cancellation, except for information that laws and regulations expressly require us to retain, your personal information will be deleted or anonymized. Before cancellation, please cancel any auto-renewing subscription if applicable. We will complete cancellation and corresponding data deletion within a reasonable period.
6. How We Use Local Cache and Similar Technologies
To maintain login status, remember preference settings, improve loading speed, and ensure service stability, this App may write cache, local storage, or similar technology information to your device locally. Such information is stored locally on your device, and you may clear it through in-App cache clearing or by deleting this App’s data in the system. Clearing it may affect the experience of using related functions. This App does not use third-party tracking Cookies and does not use such technologies to track you across apps or websites.
7. Protection of Minors
We attach great importance to protecting minors’ personal information. According to relevant national laws and regulations and the nature of this product, we decline to provide services to children under fourteen (14) years old.
If you are a minor who is at least fourteen but under eighteen years old, please read this Policy and use Lingxia-related services under the supervision and guidance of your guardian and with your guardian’s consent, and provide personal information cautiously.
We have the right to verify user identity information. If we discover that we have collected personal information of a child under fourteen years old without prior verifiable consent from the child’s parent or legal guardian, we will try to delete the relevant data as soon as possible and stop providing services to that child. If you are the guardian of a minor and have any questions about the minor’s use of the Service or the information provided, please contact us promptly through the methods in Section 9.
8. How We Update the Privacy Policy
We reserve the right to update or revise this Policy from time to time, and updates and revisions form part of this Policy. Without your explicit consent, we will not reduce the rights you should enjoy under the currently effective Policy. If this Policy undergoes major changes, we will notify you through reasonable means such as App client push notifications or in-app announcements, and obtain your consent again when necessary.
9. How to Contact Us
If you have any complaints, suggestions, or questions about personal information protection, or any questions about this Policy, you may contact us through the following methods. We will review the matter as soon as possible and respond within fifteen working days after verifying your identity:
Company name: FORTUNETELL AI LIMITED
Personal information protection/customer service contact email: contact@fortunetell.ai
If you believe our personal information processing activities have harmed your lawful rights and interests, you may also file a complaint or report with relevant authorities such as cyberspace, telecommunications, public security, or market regulation authorities.
10. Miscellaneous
The formation, effectiveness, interpretation, performance, and dispute resolution of this Policy are governed by the laws of Mainland China. Any dispute arising from this Policy or our processing of your personal information shall be resolved through friendly negotiation between the parties. If negotiation fails, either party has the right to submit the dispute to the people’s court with jurisdiction at the Operator’s domicile. The invalidity of any provision of this Policy does not affect the validity of the remaining provisions.