Official Privacy Policy

This Privacy Policy describes the policies and procedures of Beijing Tongming Technology And Trade Co., Ltd. ("the Company", "we", "us", or "our") on the collection, use, and disclosure of your information when you use our mobile applications, games, and website (the "Service"). We are committed to protecting your personal data and your right to privacy in accordance with global standards.

1. Global Privacy Framework and Data Adaptation

We adhere to the following international data protection principles to ensure user data is handled securely across different jurisdictions:

• GDPR (EU/EEA): Processing is based on legal grounds such as consent, contract necessity, or legitimate interests.
• CCPA/CPRA (USA): Providing California residents with the right to know, delete, and opt-out of the sale/sharing of personal information.
• Global Data Localization: While we operate globally, we respect local data residency requirements where applicable.

1.1 Categories of Data Collected

To provide a high-quality user experience, we collect the following types of information:

• Technical Identifiers: Including but not limited to IP addresses, Advertising IDs (IDFA, AAID), device models, and operating system versions.
• Usage Data: In-app behavior, feature engagement, session duration, and crash logs to improve software stability.
• Preference Data: Language settings, localized time zones, and user-selected in-app configurations.

2. Global Age Management and Children's Privacy

Our Service is designed for a global audience, and we implement strict age-verification protocols adapted to regional legal requirements:

• COPPA Compliance (United States): We do not knowingly collect personal information from children under the age of 13. If a service is directed towards children, we implement a "neutral age screen" and do not collect identifiers for behavioral advertising without verifiable parental consent.
• GDPR-K (European Union): For users under the age of 16 (or lower as defined by member states), we require explicit consent from the holder of parental responsibility.
• Global Standards: In all other jurisdictions, we comply with the local digital age of consent. If we become aware that we have collected personal data from a minor without appropriate consent, we will take immediate steps to delete that information from our servers.

3. Third-Party Monetization and Analytics Adaptation

Our Services integrate with professional third-party SDKs for monetization and performance tracking. These partners (e.g., Google AdMob, Unity Ads, AppLovin, Firebase) may collect data according to their own privacy policies. We ensure that these partners are compliant with global privacy standards and provide users with the ability to manage their tracking preferences via device settings.

4. Data Protection and Security Measures

The Company employs industry-standard administrative, technical, and physical security measures to protect the confidentiality, integrity, and availability of your personal data. This includes encryption (SSL/TLS), access controls, and regular security audits.

5. International Data Transfers

Your information may be transferred to, and maintained on, computers located outside of your state, province, or country. We utilize Standard Contractual Clauses (SCCs) and other approved legal mechanisms to ensure your data receives the same level of protection as it would in its country of origin.

6. Contact and Data Subject Rights

Users have the right to access, rectify, or delete their personal data. To exercise these rights or for any inquiries regarding our privacy practices, please contact our Data Protection Office at support@bjtongming.com.