Privacy Policy

Last updated: 23 October 2026

This policy explains what personal information we collect when you visit this website, order a Traditional Chinese Wellness Analysis (“the Report”), or contact us — and what we do with it. We have tried to write it in plain English rather than in the usual tangle.

1. Who we are

The Report is operated by an individual sole proprietor established in the Hong Kong Special Administrative Region. For the purposes of the EU and UK General Data Protection Regulation, we are the data controller of the personal data described below.

Contact for any privacy matter: qiaoyingfeng1319@gmail.com

2. What we collect

Category	What it includes	Why
Contact data	Your email address.	To deliver the Report and reply to you.
Wellness profile data (special category)	Your answers to the questionnaire: sleep, sensitivity to cold, digestion, energy, temperament, build, seasonal patterns and stress.	To compose your personalised Report. This is information concerning health and is treated as special category data.
Transaction data	PayPal transaction identifier, amount, currency, payment status and the email address associated with the payment.	To confirm payment, match it to your order, and keep delivery records.
Delivery records	Time the Report was sent, the recipient email address, and a cryptographic hash (SHA-256) of the file delivered.	To evidence that the digital product was delivered as described.
Technical data	IP address, browser user-agent, and the time of your submission.	Security, fraud prevention, and evidencing your consent.

We do not collect or store your card number, bank details or PayPal password. Payment is handled entirely by PayPal on its own systems. We also do not collect any postal or shipping address — we sell digital products only, and nothing is physically dispatched.

3. Our lawful basis

• Explicit consent (Art. 6(1)(a) and Art. 9(2)(a) GDPR) — for the wellness profile data. We ask for this separately and specifically, with a checkbox, before you can submit the questionnaire. You may withdraw it at any time.
• Performance of a contract (Art. 6(1)(b)) — to deliver the Report you have ordered.
• Legitimate interests (Art. 6(1)(f)) — to keep records that let us defend against payment disputes, and to keep the site secure. We have balanced this against your rights and consider the intrusion minimal.
• Legal obligation (Art. 6(1)(c)) — where we are required to retain or disclose records.

4. How we use it

We use your information only to: compose and email your Report; respond to your enquiries; verify and record payment and delivery; and meet our legal and accounting obligations. We do not use your data for advertising, profiling, or automated decision-making, and we do not sell it.

5. Who we share it with

Only with the service providers we need to run the business, and only to the extent necessary:

• PayPal — to process your payment. PayPal is an independent controller of the payment data it collects; see PayPal’s own privacy statement.
• Our email provider — to send the Report and service messages.
• Our hosting provider — servers located in Hong Kong.

We may also disclose information where we are legally required to, or to establish or defend a legal claim.

6. International transfers

We operate from Hong Kong. If you are in the European Economic Area, the United Kingdom or Switzerland, your data will be transferred outside those regions. Where we transfer special category data to a processor outside the EEA or UK, we rely on an appropriate transfer mechanism (such as the European Commission’s Standard Contractual Clauses) together with the safeguards required by law.

7. How long we keep it

• Wellness profile data — kept until your Report is delivered and any dispute window has closed, then deleted within 12 months, unless you ask us to delete it sooner.
• Transaction and delivery records — kept for 3 years from the date of the order, because payment disputes and consumer claims can be brought within that period. This is also our legitimate interest in being able to defend a claim.
• Consent records (time, IP, version of the consent text) — kept for the same 3 years, because the law requires us to be able to demonstrate that consent was given.

8. Your rights

Subject to applicable law, you have the right to:

• be informed about how we use your data (this page);
• access a copy of the data we hold about you;
• have inaccurate data corrected;
• have your data erased, where we no longer have a lawful reason to keep it;
• restrict or object to certain processing;
• receive your data in a portable format;
• withdraw your consent at any time — this does not affect processing carried out before you withdrew it;
• lodge a complaint with your local supervisory authority (in the UK, the Information Commissioner’s Office; in the EU, the authority in your member state).

To exercise any of these, write to qiaoyingfeng1319@gmail.com. We respond within one month. Exercising your rights is free.

9. Cookies and tracking

This website sets no cookies, uses no analytics, and loads no third-party scripts, fonts or pixels. Everything is served from our own server. The only third party you interact with is PayPal, and only after you click the payment button — at which point PayPal’s own cookie and privacy policies apply.

10. Security

Data is transmitted over HTTPS. Access to our records is restricted to the operator. We keep an immutable log of questionnaire submissions, consent timestamps and delivery records so that any dispute can be resolved on evidence rather than recollection. No system is perfectly secure, but we take reasonable technical and organisational measures appropriate to the sensitivity of the data.

11. Children

The Report is intended for adults aged 18 and over. We do not knowingly collect data from anyone under 18. If you believe a minor has submitted information, contact us and we will delete it.

12. Changes

If we change this policy, we will update the date at the top. Material changes affecting how we use your data will be notified by email to anyone with an open order.

13. Contact

Questions, requests or complaints: qiaoyingfeng1319@gmail.com

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