Privacy Policy

Last Updated: December 15, 2024

1. Introduction

Beijing Jiujiujia Property Management Co., Ltd. ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, transfer, and store your personal information when you use our website at bjjiujiujia.com (the "Website") and our mobile applications available on Google Play and App Store (the "Apps").

This policy applies to all users worldwide and complies with various international privacy laws including GDPR, CCPA, COPPA, PIPEDA, LGPD, PDPA, APPI, and other applicable privacy regulations. By using our Website and Apps, you consent to the data practices described in this policy.

2. Information We Collect

2.1 Personal Information You Provide

  • Name, email address, phone number, and postal address
  • Property information and management preferences
  • Payment information for service transactions
  • Account credentials and authentication information
  • Communications and feedback you provide to us
  • Images and documents you upload (ID verification, property photos)

2.2 Automatically Collected Information

  • Device identifiers (IDFA, GAID)
  • IP address and geographic location
  • Browser type and version
  • Operating system information
  • Device characteristics and specifications
  • Usage patterns and behavioral data
  • App crash reports and performance data
  • Cookies and similar tracking technologies

2.3 Information from Third Parties

  • Social media platform information (if you choose to connect)
  • Analytics and advertising partners
  • Payment processors and financial institutions
  • Public databases and property records

3. GDPR Compliance (European Union)

If you are located in the European Economic Area (EEA), we process your personal data in accordance with the General Data Protection Regulation (GDPR). Under GDPR, we rely on the following legal bases:

3.1 Legal Basis for Processing

  • Consent: You have given clear consent for us to process your personal data for specific purposes
  • Contract: Processing is necessary for a contract we have with you
  • Legal Obligation: Processing is necessary for us to comply with the law
  • Legitimate Interests: Processing is necessary for our legitimate interests, provided your rights don't override those interests

3.2 EU Data Subject Rights

If you are an EU resident, you have the following rights:

  • Right to Access: Obtain confirmation of whether we process your data and access your personal data
  • Right to Rectification: Have inaccurate personal data corrected
  • Right to Erasure: Request deletion of your personal data ("right to be forgotten")
  • Right to Restrict Processing: Request limitation of data processing
  • Right to Data Portability: Receive your data in a structured, machine-readable format
  • Right to Object: Object to processing based on legitimate interests
  • Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent
  • Right to Lodge Complaint: File a complaint with a supervisory authority (EU Data Protection Authorities)

3.3 Data Transfers

When we transfer data outside the EEA, we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission. You may request details of these safeguards by contacting us.

4. CCPA Compliance (California, USA)

If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with specific rights regarding your personal information.

4.1 Your California Privacy Rights

  • Right to Know: Request disclosure of personal information collected, used, disclosed, or sold
  • Right to Delete: Request deletion of personal information held by us
  • Right to Opt-Out: Opt-out of the sale of personal information (Note: We do not sell personal information)
  • Right to Non-Discrimination: Not be discriminated against for exercising your privacy rights

4.2 Categories of Personal Information Collected

In the past 12 months, we may have collected the following categories of personal information:

  • Identifiers (name, email, phone, IP address, device IDs)
  • Commercial information (property details, transaction history)
  • Internet activity (browsing history, app usage)
  • Geolocation data
  • Professional or employment-related information
  • Inferences drawn from collected information

4.3 California Shine the Light Law

California residents who have provided personal information in connection with a business transaction may request information about whether we share certain categories of personal information with third parties for direct marketing purposes.

5. COPPA Compliance (Children's Privacy - USA)

We comply with the Children's Online Privacy Protection Act (COPPA). Our services are not directed to children under 13 years of age.

5.1 Age Restrictions

  • Minimum Age: Users must be at least 13 years old to create an account
  • Under 13: We do not knowingly collect personal information from children under 13
  • Parental Contact: If you believe we have collected information from a child under 13, contact us immediately

5.2 Parental Rights

Parents or guardians of children under 13 may:

  • Review personal information collected from their child
  • Request deletion of their child's personal information
  • Refuse further collection or use of their child's information
  • Consent to collection without consenting to third-party disclosure

6. PIPEDA Compliance (Canada)

We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) for Canadian users.

6.1 Canadian Privacy Rights

  • Access: Right to access your personal information
  • Accuracy: Right to challenge the accuracy and completeness of your information
  • Correction: Right to have inaccurate information corrected
  • Knowledge: Right to be informed about why we collect, use, or disclose your information
  • Consent: Right to withhold or withdraw consent (subject to legal requirements)

6.2 Accountability and Security

We are accountable for protecting personal information under our control and have implemented appropriate security measures to safeguard personal information against unauthorized access, disclosure, or destruction.

7. LGPD Compliance (Brazil)

For users in Brazil, we process personal data in accordance with the Lei Geral de Proteção de Dados (LGPD - General Data Protection Law).

7.1 Legal Bases for Processing (Article 7)

  • Consent of the data subject
  • Compliance with legal or regulatory obligations
  • Execution of public policies
  • Studies by research bodies
  • Execution of contract or preliminary procedures
  • Exercise of rights in judicial, administrative, or arbitral proceedings
  • Protection of life or physical safety
  • Legitimate interests of the controller or third party

7.2 LGPD Rights

  • Confirmation of existence of processing
  • Access to personal data
  • Correction of incomplete, inaccurate, or outdated data
  • Anonymization, blocking, or deletion of unnecessary data
  • Data portability
  • Deletion of personal data processed with consent
  • Information about sharing with third parties
  • Information about possibility of denying consent
  • Revocation of consent

8. PDPA Compliance (Thailand)

We comply with Thailand's Personal Data Protection Act (PDPA) for users located in Thailand.

8.1 Lawful Bases for Processing

  • Consent from the data subject
  • Performance of contract
  • Compliance with law
  • Legitimate interests
  • Public task or exercise of official authority
  • Vital interests of the data subject

8.2 Rights Under PDPA

  • Right to withdraw consent
  • Right to access and obtain copy
  • Right to data portability
  • Right to object
  • Right to erasure
  • Right to restriction
  • Right to correction

9. APPI Compliance (Japan)

We comply with Japan's Act on Protection of Personal Information (APPI) for users in Japan.

9.1 Purposes of Use

We use personal information only for the following purposes:

  • Providing our services
  • Responding to inquiries
  • Sending notices about services
  • Improving our services
  • Developing new services
  • Ensuring service quality and security

9.2 Rights Under APPI

  • Right to request disclosure of retained personal data
  • Right to request correction
  • Right to request cessation of use or deletion
  • Right to refuse provision to third parties

10. China Personal Information Protection Law (PIPL)

For users in China, we comply with the Personal Information Protection Law (PIPL) of the People's Republic of China.

10.1 Legal Bases for Processing

  • Consent of the individual
  • Necessary for performance of contract
  • Necessary for fulfilling legal obligations
  • Necessary for responding to public health emergencies
  • Necessary for news reporting, public opinion supervision
  • Necessary for protecting vital interests of individuals
  • Necessary for other legitimate purposes

10.2 Individual Rights

  • Right to know and decide
  • Right to restrict or deny others' collection and use
  • Right to consult and duplicate
  • Right to request correction
  • Right to request deletion
  • Right to explanation
  • Right to withdraw consent
  • Right to lodge complaints

10.3 Cross-Border Transfers

For cross-border transfers of personal information, we comply with PIPL requirements including security assessments, standard contracts, or certifications as required.

11. Australian Privacy Compliance

We comply with the Australian Privacy Act 1988 and the Australian Privacy Principles (APPs) for users in Australia.

11.1 Australian Privacy Principles

  • APP 1: Transparency and accountability in information handling
  • APP 3: Collection of solicited personal information
  • APP 5: Notification of collection of personal information
  • APP 6: Use and disclosure of personal information
  • APP 7: Direct marketing (with opt-out rights)
  • APP 8: Cross-border disclosure of personal information
  • APP 11: Security of personal information
  • APP 12: Access and correction rights

11.2 Notifiable Data Breaches

In case of an eligible data breach, we will notify the Australian Information Commissioner and affected individuals as required under the Notifiable Data Breaches scheme.

12. Cookie Policy

We use cookies and similar technologies to enhance your experience on our Website and Apps.

12.1 Types of Cookies We Use

  • Essential Cookies: Required for basic site functionality
  • Performance Cookies: Help us understand how visitors use our site
  • Functionality Cookies: Remember your preferences and settings
  • Advertising Cookies: Used to deliver relevant advertisements
  • Analytics Cookies: Help us analyze usage patterns

12.2 Managing Cookies

You can control cookie settings through your browser or device. Disabling cookies may affect site functionality. For mobile apps, you can manage advertising identifiers through your device settings.

13. Advertising and Third-Party Ad Networks

Our Apps include advertising from various third-party ad networks. These networks collect and use device and usage data to serve personalized and non-personalized advertisements.

13.1 Integrated Advertising Platforms

We may integrate the following advertising and monetization platforms:

13.1.1 Google AdMob

Our Apps use Google AdMob for advertising. Google collects and uses data according to its Privacy Policy. You can opt-out of personalized advertising through your device settings or Google's ad settings.

  • Splash advertisements (full-screen ads displayed at app launch)
  • Rewarded video advertisements (users receive rewards for viewing)
  • Interstitial advertisements (full-screen ads between content)
  • Banner advertisements (display ads within app interface)
  • Native advertisements (ads integrated into app content)

13.1.2 Facebook Audience Network

Our Apps may use Facebook Audience Network for advertising. Facebook's data collection and use is governed by Facebook's Data Policy. Users can control ad preferences through Facebook settings.

  • Video advertisements
  • Interstitial ads
  • Banner ads
  • Native ads
  • Rewarded videos

13.1.3 Unity Ads

Unity Ads provides advertising services for our mobile applications. Unity collects data according to its Privacy Policy for serving advertisements and measuring ad performance.

  • Video ads (non-skippable and skippable)
  • Playable ads
  • Display ads
  • Rewarded ads

13.1.4 AppLovin

AppLovin provides mobile advertising and monetization solutions. AppLovin's data practices are governed by its Privacy Policy and Platform Terms.

  • Native ads
  • Interstitial ads
  • Rewarded video ads
  • Banner ads
  • Personalized recommendations

13.1.5 IronSource

IronSource provides advertising and monetization services. IronSource's data collection is governed by its Privacy Policy.

  • Interstitial ads
  • Rewarded video ads
  • Banner ads
  • Native ads
  • Offer wall ads

13.1.6 Vungle

Vungle (by Chartboost) provides advertising services including high-quality video ads. Vungle's data practices follow its Privacy Policy.

  • Dynamic end-cards
  • Interstitial video ads
  • Rewarded video ads

13.1.7 Chartboost

Chartboost provides mobile game advertising and monetization. Chartboost's data collection is governed by its Privacy Policy.

  • Interstitial ads
  • Rewarded video ads
  • Native ads

13.1.8 MoPub (Tencent)

MoPub (operated by Tencent) provides mobile advertising mediation. MoPub's data practices are governed by its Privacy Policy.

  • Banner ads
  • Interstitial ads
  • Rewarded video ads
  • Native ads

13.1.9 Pangle (ByteDance)

Pangle by ByteDance provides advertising services. Pangle's data collection follows its Privacy Policy and applicable regulations.

  • Video ads
  • Native ads
  • Interstitial ads
  • Rewarded ads

13.1.10 Start.io (formerly StartApps)

Start.io provides mobile advertising and analytics. Start.io's data practices follow its Privacy Policy.

  • Interstitial ads
  • Native ads
  • Recommended content

13.1.11 AdColony

AdColony provides mobile video advertising. AdColony's data collection is governed by its Privacy Policy.

  • Instant-feed video ads
  • Rewarded video ads
  • Display ads

13.1.12 InMobi

InMobi provides mobile advertising and analytics services. InMobi's data practices follow its Privacy Policy.

  • Video ads
  • Native ads
  • Interstitial ads
  • Personalized ads

13.1.13 Tapjoy

Tapjoy provides mobile advertising and monetization. Tapjoy's data collection is governed by its Privacy Policy.

  • Rewarded video ads
  • Offer wall ads
  • Interstitial ads

13.1.14 Additional Ad Platforms

We may also integrate with other advertising platforms including but not limited to:

  • Mintegral
  • Appnext
  • CrossInstall
  • Fyber
  • OpenX
  • Smaato
  • Ogury
  • Liftoff
  • Verve
  • Digital Turbine
  • Adjust
  • AppsFlyer
  • Branch
  • Singular
  • GameAnalytics

13.2 Ad Types We Use

  • Splash Ads: Full-screen advertisements displayed when the app launches or transitions between activities
  • Rewarded Video Ads: Full-screen video advertisements where users voluntarily watch to earn in-app rewards (coins, extra lives, premium features)
  • Interstitial Ads: Full-screen advertisements displayed at natural transition points (between levels, after completing actions)
  • Banner Ads: Rectangular display advertisements displayed persistently or temporarily at top or bottom of screen
  • Native Ads: Advertisements designed to match the visual style and behavior of the app interface
  • Video Ads: Standalone video advertisements that may be skippable or non-skippable
  • Playable Ads: Interactive advertisements that allow users to try a mini-version of the advertised app
  • Offer Wall Ads: Displays multiple advertising offers that users can complete for rewards

13.3 Data Used for Advertising

Advertising networks may collect and use:

  • Device identifiers (IDFA, GAID)
  • Device type and specifications
  • Operating system and version
  • IP address and approximate location
  • App usage patterns and in-app behavior
  • Interaction with advertisements
  • Crashes and performance metrics

13.4 Opting Out of Personalized Advertising

You can opt-out of personalized advertising in the following ways:

  • iOS (Apple): Settings > Privacy > Advertising > Enable "Limit Ad Tracking"
  • Android (Google): Settings > Google > Ads > Enable "Opt out of Ads Personalization"
  • Device Settings: Many advertising platforms respect the device's advertising identifier opt-out settings
  • In-App Settings: Some apps may offer ad preferences within the application

Note: Even if you opt-out, you may still receive non-personalized advertisements based on contextual information.

14. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction.

14.1 Security Measures Include

  • Encryption of data in transit (TLS/SSL)
  • Encryption of sensitive data at rest
  • Regular security assessments and audits
  • Access controls and authentication requirements
  • Employee training on data protection
  • Incident response procedures
  • Third-party security assessments

14.2 Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, including for legal, accounting, or reporting requirements. When information is no longer needed, we securely delete or anonymize it.

15. Your Rights and Choices

You have various rights and choices regarding your personal information:

15.1 General Rights

  • Access: Request access to your personal information
  • Correction: Request correction of inaccurate data
  • Deletion: Request deletion of your data (subject to legal requirements)
  • Portability: Request a copy of your data in machine-readable format
  • Objection: Object to certain processing activities
  • Restriction: Request restriction of processing in certain circumstances
  • Withdraw Consent: Withdraw consent where processing is based on consent

15.2 Communication Preferences

You can manage your communication preferences:

  • Opt-out of marketing emails by clicking unsubscribe
  • Adjust notification settings in our Apps
  • Contact us to update your preferences

15.3 Location Services

Our Apps may collect location data. You can control location permissions through your device settings.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by:

  • Posting the updated policy on our Website
  • Updating the "Last Updated" date
  • Sending push notifications through our Apps (where applicable)
  • Sending email notifications to registered users

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

17. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your rights, or need assistance, please contact us:

17.1 Company Information

Beijing Jiujiujia Property Management Co., Ltd.
Buildings 1 through 6 (including Building 1, Units 241, 242, and 243 on the 2nd floor)
No. 9 Kangbao Road, Miyun District
Beijing, China

17.2 Contact Methods

Email: info@bjjiujiujia.com
VIP/Business: zhengxiuzhu@bjjiujiujia.com
Website: www.bjjiujiujia.com

17.3 Response Time

We will respond to your requests within 30 days. For complex requests or requests from multiple users, we may extend this period by an additional 30 days with notice.

18. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws. When we transfer personal information internationally, we ensure appropriate safeguards are in place, which may include:

  • Standard Contractual Clauses (SCCs) approved by relevant authorities
  • Binding Corporate Rules for intra-group transfers
  • Certification mechanisms
  • Codes of conduct approved by supervisory authorities

19. California-Specific Provisions (CCPA Section 1798.83)

California residents may request information about any third parties to whom we disclose personal information for direct marketing purposes. To make such a request, please contact us using the information provided above.

20. Do Not Track Signals

We do not currently respond to "Do Not Track" signals from web browsers. We may adopt a response to these signals if a standard is established. You can manage your advertising preferences through the settings described in this policy.