Te Hub Privacy Policy
Te Hub App Privacy Policy
Effective Date: January 30, 2026
Welcome to the Te Hub App (hereinafter referred to as the "App"), which is independently developed and operated by Yelfan Trading Limited (hereinafter referred to as "we", "us" or "the Company"). This Privacy Policy is formulated in accordance with the Google Play Store Listing Guidelines and major global data protection laws and regulations, aiming to fully and transparently inform you of our practices regarding the collection, use, storage, sharing, and protection of your personal data, as well as your core rights and the ways to exercise them in data processing activities.
This App is only available to users aged 18 and above. We do not collect any personal information of minors under the age of 18, and have taken technical measures to prevent minors from accessing and using this App. This App supports two usage modes: login mode and guest mode. In guest mode, you can experience basic browsing functions; after logging in, you can unlock all functions (including publishing works, in-app purchases, etc.) and associate personal data. At the same time, this App is equipped with in-app purchase functions to support the redemption of relevant rights and interests for publishing works. For specific rules, please refer to the following instructions. Please carefully read and fully understand all terms of this Policy before using this App; if you do not agree to any content of this Policy, please do not download or use this App.
1. Core Definitions
• Personal Data: Refers to any information relating to an identified or identifiable natural person, including but not limited to your device information, usage behavior records, pictures and audio uploaded through this App, login information, in-app purchase related data, etc.
• Data Controller: Refers to a legal person who determines the purposes and methods of personal data processing. For the purposes of this Policy, the Data Controller is Yelfan Trading Limited.
• Data Protection Officer (DPO): A dedicated person responsible for supervising the compliance of the Company's data processing activities and responding to user requests related to data. For the contact information of the Data Protection Officer, please refer to Article 2 of this Policy.
• Data Sale/Sharing: "Data Sale" refers to the disclosure of personal data to a third party in exchange for commercial consideration in accordance with applicable laws; "Data Sharing" refers to the disclosure of personal data to a third party beyond the purposes agreed in this Policy (excluding data transmission necessary for realizing the core functions of this App).
• Login Function: Refers to the function that allows users to verify their identity through mobile phone numbers, email addresses, third-party accounts (such as Google Accounts), log in to this App and associate personal account information. After logging in, you can unlock all functions such as publishing works, in-app purchases, and data synchronization.
• In-app Purchase Function: Refers to the function that allows users to purchase virtual currency (coins) through the in-app payment channel of this App for redeeming services related to publishing works. This App will provide newly logged-in users with 50 free coins for free to publish works. Each subsequent work published will cost 5 coins. Coins can only be used for services related to publishing works in this App, and cannot be cashed or transferred.
• Applicable Laws: Including but not limited to the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), Virginia Consumer Data Protection Act (VCDPA), Brazil's General Data Protection Law (LGPD), United Arab Emirates' Federal Data Protection Law (FADP), and other data protection laws and regulations in major global jurisdictions.
2. Details of the Data Controller and Data Protection Officer (DPO)
• Name of Data Controller: Yelfan Trading Limited
• Registered Address: Unit 21, 11/F, Tin Wai Industrial Building, No. 3 Hing Wong Street, Tuen Mun, Hong Kong
• Official Contact Email: wanghongkong6@gmail.com
• Data Protection Officer (DPO): Lily DPO Contact Email: wanghongkong6@gmail.com
3. Scope and Methods of Information Collection
We strictly follow the principles of "legality, legitimacy, and necessity", and only collect personal data necessary for realizing the functions of this App, without collecting additional irrelevant information. The specific scope and methods are as follows:
3.1 Personal Data Voluntarily Provided by You
• Published Content Data: When you use the publishing function of this App to share your Christmas tree decoration achievements, you need to take real-time photos with the camera or select pictures from the album. We will collect such picture data to display your works in the community and realize sharing and interaction functions. You can independently choose whether to publish and have the right to delete published content at any time. Publishing works requires consuming coins. Newly logged-in users can use the 50 free coins to publish works, and each subsequent work published will cost 5 coins.
• Feedback Data: When you submit suggestions or questions through the feedback template in the "Personal Center", you can choose to use the recording function (which relies on microphone permission). We will collect your audio data to accurately handle feedback and optimize product experience; you can also choose to submit feedback in text form, and the recording function is not mandatory.
• Personal Profile Data: You can independently edit and fill in information such as avatar, nickname, personal signature, and Christmas decoration preferences. Such data will be displayed in your personal center for identity recognition in community interactions, and you can modify or delete such information at any time.
• Login-related Data: When you choose to log in to this App, we will collect your login account information (such as mobile phone number, email address, third-party account authorization information, etc.), login time, and login device information to verify your identity, ensure account security, associate your published content, in-app purchase records with your personal account. Such data is only collected when you actively complete the login operation, and is not collected in guest mode.
• In-app Purchase-related Data: When you use the in-app purchase function of this App, we will collect your in-app purchase order information (order number, purchase time, purchase amount), coins acquisition and consumption records (including the arrival record of 50 free coins and the record of consuming 5 coins for publishing each work), and desensitized information related to the payment account (only used for payment verification and order verification, and no complete payment account information is stored) to complete in-app purchase transactions, fulfill coins rights and interests, and handle after-sales issues related to in-app purchases.
3.2 Automatically Collected Personal Data
• Basic Device Information: When you start and use this App, we will automatically collect your device model, operating system version, device ID, unique device identifiers (such as IMEI, Android ID, IDFA, etc., only used for device identification and function adaptation), network type (Wi-Fi/mobile network), IP address and other information. The purpose is to ensure the stable operation of this App on your device, troubleshoot technical faults, optimize performance, and count the scale of legitimate users.
• Usage Behavior Data: We will collect your usage behavior records in this App, including but not limited to favorite content, likes/comments/follows, search keywords, relevant information of published content (publishing time, tags, descriptions, number of coins consumed), usage records of practical tools, login status, in-app purchase behavior records, coins consumption and remaining quantity, etc. This data is used for personalized recommendations, optimizing content distribution logic, counting in-app purchase conversion, ensuring the normal use of coins rights and interests, and improving user experience.
• Permission Usage Status Data: We will record the authorization status of various permissions of this App (such as the on/off status of permissions for camera, album, microphone, external storage, app information reading, etc.) to ensure the normal call of functions and compliance management. Permission status is only stored locally on your device and on our secure servers.
3.3 Explanation of Data Collection Methods
• Voluntary Provision: Data generated based on your voluntary operations, including uploading pictures, recording feedback audio, editing personal profiles, using interaction functions, actively logging in to accounts, and conducting in-app purchase operations.
• Automatic Collection: Automatically obtained through the background system of this App during the operation of functions, without additional manual operations from you. The collection process is completely transparent and does not affect your user experience.
• Permission Dependence: All information collection involving device permissions requires your explicit authorization before using the corresponding functions; you can modify the permission authorization status in the device system settings at any time. However, turning off necessary permissions (such as camera/album permissions required for the publishing function) may cause the corresponding functions to be unavailable, but will not affect the availability of other irrelevant functions.
3.4 Detailed Explanation of Device Permissions Collected by This App
We clearly list the device permissions that this App needs to collect, as well as the collection methods, core usage scenarios, collection purposes, and data processing methods, to ensure that permission collection and use fully comply with the principles of "legality, necessity, and transparency", and fully protect your right to know and right to choose.
Camera Permission
• Collection Method: Explicitly authorized by you; when you use the publishing function for the first time, this App will send a permission request through a pop-up window, and you can independently choose to agree or refuse.
• Core Usage Scenarios: Focus on the publishing page, only used for you to take real-time photos of Christmas tree decoration scenes, supporting scenarios such as recording decoration achievements and phased progress. Publishing works requires consuming coins (50 free coins for new users, 5 coins per subsequent work).
• Collection Purpose: Support the core scenarios of the publishing function, allowing you to quickly capture wonderful moments during the decoration process and share them with the community. Original shooting data is not additionally stored, only the pictures you finally choose to publish are retained.
• Data Processing: Only collect the picture data you actively choose to publish; encryption technology is used during transmission to ensure security, and data is stored on secure servers that meet data protection standards. You can delete published content and corresponding pictures at any time through in-app functions. After deletion, the relevant data (including backup data) will be completely cleared within 7 working days.
Album Permission
• Collection Method: Explicitly authorized by you; when you use the publishing function for the first time, a permission request is sent through a pop-up window, and the decision is completely in your hands.
• Core Usage Scenarios: Publishing page, supporting you to select already taken Christmas tree decoration pictures from the device album, meeting the needs of multi-picture upload, and facilitating the sharing of historically taken decoration cases, achievement pictures, etc. Publishing works requires consuming coins (50 free coins for new users, 5 coins per subsequent work).
• Collection Purpose: Improve the convenience of the publishing function, allowing you to upload existing materials without re-shooting. Only read the picture files you actively select, and do not access other irrelevant unselected pictures in the album.
• Data Processing: Only read and obtain the picture data you choose to upload; do not scan or store unselected pictures in the album. All data transmission and storage use encryption technology to ensure information security, and unuploaded album pictures are always under your independent control.
Microphone Permission
• Collection Method: Explicitly authorized by you; when you use the feedback function for the first time, this App will send a permission request through a pop-up window, and you can choose to agree or refuse to use it.
• Core Usage Scenarios: Feedback template in the Personal Center, only used for you to record voice feedback, facilitating the quick submission of product suggestions, usage problems or optimization needs (such as issues related to in-app purchases, login, and publishing works), and improving feedback efficiency.
• Collection Purpose: To more accurately handle your feedback needs. Voice data is only used to respond to your needs and optimize product experience, with no other uses.
• Data Processing: Only collect the voice data you actively record and submit, with a maximum storage period of 6 months (after the feedback is completely processed, the data will be automatically anonymized). Encryption technology is used during transmission to protect privacy. Voice data will not be disclosed to any third party, and only relevant internal responsible persons can view it when handling feedback.
External Storage Permission
• Collection Method: Explicitly authorized by you; when you use the publishing function or favorite function for the first time, this App will send a permission request through a pop-up window, and you can independently decide whether to grant it.
• Core Usage Scenarios: (1) Cache edited pictures in the publishing function to ensure the smoothness of picture cropping, filter addition and other editing operations, and publishing works requires consuming coins; (2) Cache favorite high-quality content pictures in the favorite function to support offline viewing of favorite inspiration cases; (3) Store local data such as decoration lists and matching schemes of the virtual Christmas tree decoration simulator in the practical tool usage scenarios; (4) Cache in-app purchase related vouchers and coins balance records to ensure the normal use of the in-app purchase function.
• Collection Purpose: Optimize the user experience of this App, ensure the smooth operation of relevant functions, only occupy the necessary storage space of the device, and never access other irrelevant files in the external storage (such as documents, videos, other app data, etc.).
• Data Processing: Only store cache data and tool-generated data directly related to the functions of this App. You can apply to delete relevant data through email at any time. After uninstalling this App, all data related to this App in the device's external storage will be automatically and completely cleared without residue.
App Information Reading Permission
• Collection Method: Automatically obtained when this App starts, without additional operations from you. The permission acquisition process is transparent and does not affect device operation.
• Core Usage Scenarios: During the background operation of this App, it is used to read basic information of the App on the device, including app version number, installation time, operation status, etc., to ensure the stable operation of functions such as login, in-app purchase, and publishing works.
• Collection Purpose: Adapt to different device environments, ensure the stable operation of this App on your device, accurately troubleshoot technical problems such as crashes and freezes (including login failures, in-app purchase abnormalities, abnormal coins consumption when publishing works, etc.), and optimize app compatibility and operation performance.
• Data Processing: Only collect information related to the operation of the App itself, and never read information of any other third-party apps on the device. The collected data is only used for technical optimization and fault troubleshooting. After real-time analysis, only anonymized statistical results are retained, and no original data is stored. The statistical results are only used to improve product experience and do not involve personal privacy information.
Network Permission
• Collection Method: Enabled by default after the App is installed, and you can manually turn it off in the device system settings at any time.
• Core Usage Scenarios: Cover all functional modules of this App, including loading personalized recommendation stream content, uploading pictures/short videos (including coins consumption verification), community interactions such as likes and comments, private message sending, cloud backup of decoration lists, account login verification, in-app purchase transaction payment, and synchronization of tool data such as coins balance. Without a network, only limited local functions such as the offline mode of the virtual Christmas tree decoration simulator and editing of local decoration lists are supported, and operations that require internet access such as login, in-app purchase, and publishing works cannot be completed.
• Collection Purpose: Ensure the normal provision of core services of this App, and realize key functions such as content sharing, interactive communication, data synchronization, account login, in-app purchase transactions, and coins consumption data synchronization.
• Data Processing: Only transmit necessary data required for App functions (such as published content, interaction information, tool synchronization data, login verification information, in-app purchase transaction data, coins consumption data, etc.). All data transmission uses HTTPS encryption technology to eliminate the risk of data leakage, and no data irrelevant to App functions is transmitted. Turning off network permission does not affect the normal use of local functions.
Explanation of User's Right to Control Permissions
You have full control over all permissions and can adjust the permission status at any time through device system settings or relevant in-app functions:
• After granting permissions, you can turn off any permission at any time in [Settings > Apps > Te Hub > Permissions] of the device. Turning off permissions will cause the corresponding functions that rely on the permission to be unavailable, but will not affect the availability of other irrelevant functions (such as turning off the microphone permission still allows normal use of functions such as publishing, favoriting, community interaction, login, and in-app purchase);
• This App will not restrict your use of core functions or discriminate against you (such as reducing service quality, pushing irrelevant advertisements, etc.) in any form because you turn off non-essential permissions;
• If you re-enable a permission that has been turned off later, this App will use the permission in accordance with the scope and method agreed in this special explanation, and will not collect data beyond the agreed purpose;
• The collection and use of all permissions follow the principle of "minimum necessity". If this App needs additional permissions in the future, it will clearly inform you through app pop-ups, update announcements, etc., and only collect data after obtaining your explicit consent, and update this special explanation simultaneously to protect your right to know.
Advertising Identifier Permission
• Collection Method: Automatically obtained when the App starts (if the device system supports and enables the advertising identifier function), without additional operations from you. You can turn off the availability of this identifier through device system settings.
• Core Usage Scenarios: The advertising-related functions of this App (if advertising services are launched in the future), only used to obtain the advertising identifier generated by the device system (such as Android ID, IDFA, etc., depending on the device system).
• Collection Purpose: When this App launches advertising services in the future, realize precise advertising delivery (only push advertising content related to Christmas decorations and holiday supplies), improve advertising relevance, help advertisers count advertising effects, and ensure the compliance of advertising services.
• Data Processing: Only collect the advertising identifier generated by the device system, not associate it with your personal identity information (such as name, contact information, etc.), and not combine it with data collected from other permissions for user profiling; if you do not enable the device advertising identifier function or turn off this permission later, this App will not be able to obtain the relevant identifier, which will not affect the use of core functions, but may lead to reduced accuracy of advertising delivery (if advertising services have been launched); you can reset or turn off the advertising identifier at any time in [Settings > Privacy > Advertising] of the device (the path may vary slightly for different devices). After turning it off, this App will stop obtaining this data, and the obtained identifier will be anonymized within 15 working days.
4. Purpose of Information Collection
All behaviors of us collecting personal data are centered around "providing you with better, safer and more convenient product services". The specific purposes are as follows:
4.1 Realization of Core Functions
• Picture data collected based on camera and album permissions is used to support core social functions such as publishing decoration achievements, community sharing, and work display. Publishing works requires consuming coins (50 free coins are provided to newly logged-in users, and 5 coins are consumed for each subsequent work);
• Audio data collected based on microphone permission is only used to handle your feedback, with no other uses;
• Personal profile data is used for identity recognition in the community to ensure the continuity of the interactive experience;
• Basic device information is used to adapt to different device environments and ensure the stable operation of this App;
• Login-related data is used to verify account identity, ensure account security, associate personal published content, in-app purchase records with the account, realize the full-function experience in login mode, and distinguish the functional permissions between guest mode and login mode;
• In-app purchase-related data is used to record your in-app purchase orders, coins acquisition and consumption (including the record of 50 free coins and the record of 5 coins consumed per work), complete in-app purchase transactions, fulfill coins rights and interests, handle in-app purchase after-sales, and ensure the normal linkage between the in-app purchase function and the publishing function.
4.2 Optimization of Product Experience
• Make personalized recommendations based on your browsing history, interaction preferences, login status, in-app purchase behavior, coins consumption habits and other data, accurately push decoration inspiration, popular topics and high-quality content that meet your interests, and reduce interference from invalid information;
• Analyze the overall user usage habits, function usage frequency, in-app purchase conversion, coins consumption rules, optimize the app interface layout, function processes and content distribution efficiency, and improve product usability;
• Based on your feedback (text/audio), promptly fix product defects, improve function design (including functions related to login, in-app purchase, and publishing works), and respond to your reasonable needs.
4.3 Security and Compliance Guarantee
• Monitor the operation status of the App, prevent malicious attacks, online fraud, dissemination of non-compliant content, account theft, in-app purchase fraud, malicious brushing of coins and other behaviors, and ensure the security of your account, in-app purchase rights and interests, and use environment;
• Count the scale of legitimate users, function usage data, in-app purchase behavior data, and coins issuance/consumption data for legal purposes such as completing compliance reports, accepting regulatory inspections, and counting business data.
4.4 Other Legitimate Purposes
Within the scope of obtaining your explicit consent or permitted by laws and regulations, it is used for other legitimate purposes directly related to the services of this App, and such purposes will not infringe upon your legitimate rights and interests.
5. Legal Basis for Data Processing
In accordance with major global data protection laws and regulations, the legal basis for us to process your personal data includes the following situations:
• Based on your explicit consent: For data that requires you to grant device permissions to collect (such as pictures taken by the camera, album pictures, microphone recordings), as well as personal profiles, published content, login information, and in-app purchase-related information actively provided by you, the legal basis for data processing is your explicit consent, and you can withdraw your consent at any time in accordance with the agreement of this Policy.
• Necessary for performing the service agreement: Processing relevant personal data is a necessary condition for us to provide you with the core services of this App (such as content publishing, community interaction, practical tool use, account login, in-app purchase services, coins rights and interests fulfillment, etc.); if you refuse to provide such necessary data, we will not be able to provide you with complete App services.
• To achieve legitimate business interests: On the premise of not damaging your legitimate rights and interests, process your personal data for legitimate business interests such as optimizing product experience, ensuring App security, counting user scale, counting in-app purchase data, and analyzing coins consumption rules, and such processing will not have an unreasonable impact on your rights.
• Compliance with legal obligations: Process your personal data in accordance with the mandatory requirements of laws and regulations to fulfill compliance obligations (such as responding to regulatory investigations, cooperating with legal procedures of judicial organs, complying with tax regulations, handling compliance filing related to in-app purchases, etc.).
6. Data Storage and Protection
6.1 Data Storage Instructions
• Storage Location: Your personal data will be stored on secure servers that meet global data protection standards. The storage location may be in your region or other countries/regions with sufficient data protection levels. If cross-border data transmission is involved, we will strictly comply with the provisions of applicable laws on cross-border data transmission (such as through GDPR adequacy decision, signing standard contractual clauses, etc.) to ensure the safety and compliance of the data transmission process.
• Storage Period: We only store your personal data for the necessary period required for the collection purposes agreed in this Policy. After the expiration of the period, the data will be processed in accordance with the following rules:
￮ Published Content Data (pictures, text descriptions, etc.): If you do not actively delete it, it will be stored continuously until the App stops operating or the retention period required by laws and regulations expires; if you actively delete it, we will complete the data deletion (including backup data cleaning) within 7 working days.
￮ Feedback Data (text/audio): Stored until we completely process your feedback and confirm that it is no longer needed, with a maximum storage period of 6 months, after which it will be automatically anonymized.
￮ Device Information and Usage Behavior Data: Stored for 24 months after your last use of this App; if you use this App again during this period, the storage period will be recalculated; after expiration, it will be automatically deleted or anonymized.
￮ Personal Profile Data: If you do not modify or delete it, it will be stored continuously until the App stops operating; if you modify or delete it, the original data will be immediately anonymized or deleted.
￮ Login-related Data: Account login information is stored until you actively cancel your account or the App stops operating. After canceling the account, the relevant data (including associated in-app purchase records and coins records) will be completely cleared within 7 working days;
￮ In-app Purchase-related Data: In-app purchase order records, coins issuance records (including 50 free coins), coins consumption records (including 5 coins consumed per work) and other data are stored until the App stops operating or the period required by laws and regulations expires, for after-sales verification, rights and interests tracing, and compliance filing.
• Exceptional Circumstances: If laws and regulations require mandatory data retention (such as responding to lawsuits, regulatory requirements, in-app purchase-related tax filing, etc.), we will extend the storage period within the legal scope, and only use the data to fulfill legal obligations.
6.2 Data Security Protection Measures
We attach great importance to the security of your personal data and adopt industry-high-standard technical and management measures to comprehensively prevent personal data from being unauthorized accessed, used, disclosed, tampered with, damaged or lost:
Technical Security Guarantee
• Encryption technology is used during data transmission to ensure that data is not stolen or tampered with during transmission (including sensitive data such as login information, in-app purchase transaction data, and coins records);
• Encryption technology is used for data storage. Sensitive data (such as desensitized login account information, desensitized in-app purchase payment information, and coins records) is stored in encrypted form, and only authorized personnel can obtain it through strict access control;
• Deploy firewalls, Intrusion Detection Systems (IDS), Intrusion Prevention Systems (IPS) and other protective tools to monitor and resist network attacks in real time, and prevent risks such as account theft and in-app purchase fraud;
• Regularly conduct security vulnerability scans and penetration tests on the system, promptly fix potential security risks (including vulnerabilities related to login, in-app purchase, and coins management), and maintain system security and stability.
Management Security Guarantee
• Establish a strict data access permission control system, follow the principle of "minimum necessity", and only grant personal data access permissions to a small number of authorized personnel. All access behaviors (including access to login data, in-app purchase data, and coins records) are fully traceable;
• Regularly conduct data protection compliance training for all employees to improve their data security awareness and compliance operation capabilities, clarify data protection responsibilities, and focus on strengthening the confidentiality management of login and in-app purchase related data;
• Formulate a complete data security incident emergency plan. If a data security incident such as data leakage, loss, account theft, or in-app purchase abnormality occurs, we will immediately activate the emergency response, take remedial measures to reduce losses, and promptly notify you and relevant regulatory authorities in accordance with the requirements of applicable laws.
Third-Party Service Provider Management
If it is necessary to entrust a third-party service provider to process personal data due to business needs (such as server hosting, data analysis, in-app purchase payment services, login verification services, etc.), we will sign a strict Data Processing Agreement (DPA) with the third party, clarify the third party's confidentiality obligations, data protection requirements and liability division, and continuously supervise the third party's data processing activities to ensure that they comply with the provisions of this Policy and relevant laws and regulations, especially strengthening the protection and management of login data, in-app purchase data, and coins records.
Please note that the Internet environment has inherent uncertainties. Although we have taken the above strict protection measures, we still cannot completely rule out data security risks (such as data leakage, account abnormalities, coins abnormalities caused by force majeure, hacker attacks, equipment failures and other factors beyond our control). You need to understand and bear the corresponding reasonable risks.
7. Data Sharing and Disclosure
We are committed to strictly protecting the privacy of your personal data and will not arbitrarily share or disclose your personal data to third parties. Data sharing/disclosure will only be carried out in the following limited circumstances, and all follow the principle of legality and compliance:
• Obtain your explicit consent: After your active written consent or oral confirmation, share your personal data with the third party designated by you, and the scope of sharing is limited to the content you agree to.
• Necessary for the realization of core functions: Share limited personal data with third-party service providers that provide us with necessary services such as technical support, server hosting, data analysis, in-app purchase payment services, and login verification services. Such third parties can only use your personal data within the scope of providing services for us (such as payment service providers can only obtain desensitized in-app purchase payment information, and login service providers can only obtain login verification related information), and shall not use it for any other purposes, and must comply with the confidentiality agreement and data protection requirements signed with us.
• Comply with laws and regulations or legal procedures: Disclose your personal data (including login and in-app purchase related data, only disclosed within the legal scope) when a competent authority such as a court, arbitration institution, or regulatory authority issues a subpoena, ruling or instruction in accordance with the law, or to comply with applicable laws and regulations.
• Protect legitimate rights and interests: Share or disclose your personal data within a reasonable and necessary scope to protect the legitimate rights and interests of us, you or other third parties (such as responding to fraud, handling infringement complaints, protecting personal and property safety, handling in-app purchase disputes, recovering maliciously brushed coins, etc.), and such behavior will not infringe upon your legitimate rights and interests.
• Company Merger or Asset Transfer: If we undergo company changes such as merger, acquisition, bankruptcy liquidation, or asset sale, your personal data may be transferred to the transferee as part of the company's assets. We will notify you through app pop-ups, emails, etc. before the transfer (unless otherwise stipulated by laws and regulations), and the transferee must make a written commitment to continue to comply with all terms of this Privacy Policy, especially ensuring the security of login data, in-app purchase data, and coins records; otherwise, we will terminate the data transfer.
Special Statement: Without your explicit written consent, we will not "sell" your personal data to any third party for commercial interests, including login data, in-app purchase data, coins related records, etc.
8. Core User Rights
In accordance with applicable data protection laws and regulations, as a data subject, you enjoy the following core rights, and we will provide convenient and efficient support for you to exercise such rights:
8.1 Right to Know
You have the right to know all relevant information about our collection, use, storage, and sharing of your personal data, including the purpose, method, scope, storage period, and recipient of data processing, as well as the specific rules of the login function and in-app purchase function (including the coins issuance and consumption standards) and the processing of relevant data. Such details are fully stated in this Privacy Policy. If you have further questions, you can contact us for consultation at any time.
8.2 Right of Access
You have the right to request a copy of your personal data held by us, including personal information you actively provided, published content, usage behavior records, login records, in-app purchase records, coins issuance and consumption records, etc. We will provide such data in a structured, commonly used and machine-readable format.
8.3 Right to Rectification
If you find that your personal data stored by us (such as personal profile, login information) is inaccurate, incomplete or outdated, you have the right to request us to correct or supplement such data in a timely manner; if you find abnormalities in in-app purchase records or coins records, you can contact us to verify and correct them.
8.4 Right to Erasure (Right to Be Forgotten)
You have the right to request us to delete your personal data in the following circumstances:
• The purpose of data processing has been achieved or the storage period has expired;
• You have withdrawn your consent to data processing;
• Our data processing behavior violates applicable laws and regulations or the terms of this Policy;
• You no longer use this App and there is no legal requirement to retain such data;
• Other circumstances specified in applicable laws and regulations.
If deleting data conflicts with legal retention obligations, contract performance or public interests, we will restrict the processing of such data (instead of directly deleting it) in accordance with legal requirements and explain the reasons to you; if in-app purchase related data and coins records involve legal needs such as after-sales verification and compliance filing, they will be deleted after the expiration of the legal period.
8.5 Right to Restrict Processing
You have the right to request us to restrict the processing of your personal data in the following circumstances:
• You have raised an objection to the accuracy of the data, and verification is in progress;
• The data processing behavior is illegal, but you do not want to delete the data;
• The storage period has expired, but you need the data to resolve legal disputes;
• You have withdrawn your consent, and the relevance between the consent and data processing is still being confirmed.
During the restriction period, we will not perform any other processing on the data (except storage and protection), unless we obtain your explicit consent or otherwise required by laws and regulations; during the restriction period, it will not affect your normal use of core functions such as login, in-app purchase, and publishing works.
8.6 Right to Data Portability
You have the right to request us to provide your personal data (including login records, in-app purchase records, coins records, etc.) to you or any other data controller designated by you in a structured, commonly used and machine-readable format (such as CSV, JSON). This right only applies to data processing activities based on your consent or contractual agreement, and shall not damage our legitimate rights and interests.
8.7 Right to Object to Data Sale/Sharing
You have the right to explicitly object to the sale or sharing of your personal data to third parties. For details on how to exercise this right, please refer to Article 9 of this Policy.
8.8 Right to Withdraw Consent
You can withdraw your consent to data processing at any time (such as revoking the authorization of camera, album, microphone and other permissions, canceling the login account). Withdrawing consent does not affect the legality of data processing activities carried out based on your previous consent, nor does it affect data processing activities based on other legal bases; after canceling the login account, your login-related data will be deleted, and the unused coins in in-app purchases will be processed in accordance with relevant rules (if any).
8.9 Right to Complain
If you believe that our data processing behavior has infringed upon your legitimate rights and interests, or have objections to the login function, in-app purchase function, or coins use, you have the right to complain to the data protection regulatory authority in your jurisdiction. For complaint channels, please refer to Article 10 of this Policy.
8.10 How to Exercise the Above Rights
To exercise any of the above rights, you can submit a written request to us through the official contact email stated in this Policy. The email must clearly indicate "Exercise of Rights + Specific Right Name + Your Unique Device Identifier/Login Account (if applicable)", and include necessary identity verification information (such as personal profile screenshots, login records, in-app purchase vouchers, etc.) to facilitate us to verify your identity.
We will respond within 15 working days after receiving the request; if the matter is complex and requires an extension of the processing period, we will notify you in advance, with a maximum extension period of no more than 30 working days (in line with the maximum processing period specified by laws and regulations such as GDPR).
If you entrust a third party to exercise the above rights on your behalf, you need to provide a written power of attorney and the identity information of both parties.
9. Right to Object to Data Sale/Sharing and Opt-out Mechanism
To fully protect your control over personal data, we provide a clear mechanism to object to data sale/sharing and opt out. The specific operation methods are as follows:
9.1 Object to Data Sale
• We will not sell your personal data by default. If data sale is required due to business adjustments in the future, we will separately obtain your explicit written consent in advance through prominent methods such as app pop-ups and emails.
• If you wish to explicitly object to any form of data sale, you can send an email to wanghongkong6@gmail.com to submit an application, with the email subject indicating "Object to Data Sale + Unique Device Identifier/Login Account". We will complete the registration within 10 working days after receiving the application and notify you of the processing result via email. This objection is valid for a long time unless you take the initiative to revoke it in writing later.
9.2 Opt Out of Data Sharing
If you have agreed to us sharing your personal data with third-party service providers (such as authorizing the use of specific functions, login verification, in-app purchase payment, etc.), you can opt out of such sharing at any time through the following methods: send an email to the above official email address, with the email subject indicating "Opt Out of Data Sharing + Name of Third-Party Service Provider (if known) + Unique Device Identifier/Login Account". We will stop subsequent data sharing within 15 working days and notify the relevant third parties to stop using your personal data (unless otherwise required by laws and regulations); opting out of data sharing may affect the normal use of functions such as login and in-app purchase, and we will inform you of the relevant impact in advance.
9.3 Effect Explanation
• After you object to data sale or opt out of data sharing, we will immediately stop the relevant data sale or sharing activities, but this behavior does not affect the legality of data sale or sharing activities completed based on your previous consent.
• If data sale or sharing is a necessary condition for realizing specific functions (such as login, in-app purchase), objection or opt-out may cause such functions to be unavailable. We will clearly inform you of such impact through pop-ups or emails before your operation, and you can independently decide whether to continue.
10. Additional Rights of Users in Specific Jurisdictions
In accordance with the exclusive data protection laws and regulations of some jurisdictions, users in the following regions enjoy additional rights. We will strictly comply with the legal requirements of the corresponding regions to ensure the realization of your rights:
10.1 European Union/European Economic Area (GDPR Applicable Regions)
• You have the right to request us to explain the specific legal basis for processing your personal data and the category of data recipients (especially the recipient information in the case of cross-border data transmission, including login and in-app purchase related service providers).
• If you believe that our data processing behavior violates GDPR, you can complain to the data protection regulatory authority of your member state or the European Data Protection Board (EDPB). Complaint channels can be found on the official EDPB website.
• You have the right to refuse decisions made solely on the basis of automated processing (including user profiling) that have legal effect or similar significant impact on you. This App will not make such automated decisions (including login verification and in-app purchase review do not adopt pure automated decisions).
• Involving cross-border data transmission, you have the right to know the cross-border data protection guarantee measures we take (such as standard contractual clauses, adequacy decision).
10.2 California, USA (CCPA/CPRA Applicable Region)
• You have the right to know whether your personal information has been shared, and have the right to request us to disclose the categories, sources, processing purposes and recipient categories of your personal data collected, sold or shared in the past 12 months (including login and in-app purchase related data). We will provide such disclosure report free of charge.
• You have the unconditional right to opt out of data sale, and we will not discriminate against you (such as reducing service quality, increasing fees, restricting the use of functions such as login, in-app purchase, and publishing works) because you exercise this right.
• In accordance with the requirements of CPRA, you have the right to restrict our use and disclosure of your sensitive personal information (such as desensitized login account information, desensitized in-app purchase payment information, if applicable). We will only process sensitive personal information with your explicit consent or as permitted by law.
• Your exercise of the right to erasure shall not be unreasonably restricted. After receiving a deletion request, we will delete your personal data within the legal period, unless there are statutory exceptions (such as fulfilling legal obligations, security protection, in-app purchase after-sales verification).
10.3 Virginia, USA (VCDPA Applicable Region)
• You have the right to request us to correct inaccurate personal data (such as login information, in-app purchase records, coins records), and we will correct it in a timely manner and notify you after verification.
• You have the right to opt out of the use of your data for targeted advertising, user profiling or sale, and the opt-out takes effect immediately.
• If a data breach that may cause damage to your legitimate rights and interests occurs (including login information and in-app purchase data breach), we will notify you and the Attorney General of Virginia (if applicable) within 72 hours of discovering the breach, and inform you of the category of the breached data, potential impact and the remedial measures we have taken.
10.4 Brazil (LGPD Applicable Region)
• You have the right to request us to correct, update or anonymize incomplete, inaccurate or outdated personal data (such as login information, in-app purchase records).
• When data processing may cause damage to your legitimate rights and interests, you have the right to request us to suspend the processing of the data until the risk is eliminated.
• You can complain to the Brazilian Data Protection Authority (ANPD) about any violations related to data processing (such as login data breach, in-app purchase fraud, coins abnormalities, etc.). The complaint process can be found through official ANPD channels.
• Our processing of your personal data will follow the principle of purpose limitation, only for the legitimate purposes informed in advance, and will not exceed the processing scope (such as in-app purchase data is only used for in-app purchase related services, not for other purposes).
10.5 Explanation on Exercising Additional Rights
If you are a user in the above regions, please clearly inform us of your jurisdiction when contacting us to exercise additional rights. We will provide you with exclusive support in accordance with the laws and regulations of the corresponding regions, especially providing convenient channels for the exercise of rights related to login and in-app purchase data.
11. Changes to This Privacy Policy
We may revise this Privacy Policy in accordance with the update of laws and regulations, the adjustment of Google Play Store listing policies, the iteration and optimization of product functions (including the optimization of login and in-app purchase functions, and the adjustment of coins rules), or the improvement of data processing practices.
11.1 Material Changes
If there are material changes to this Policy (including but not limited to significant adjustments to the purpose, scope, method and sharing rules of data collection, core changes to user rights, significant updates to applicable laws, core rule adjustments to login/in-app purchase functions, and changes to coins issuance and consumption standards), we will notify you through prominent methods such as app pop-ups and push notifications. You need to re-check and confirm your consent before continuing to use this App; if you do not agree to the revised Policy, you can stop using this App, and we will respect your choice. Unused coins will be processed in accordance with relevant rules (if any).
11.2 Non-Material Changes
If the changes are non-substantive adjustments (such as optimization of text expression, update of contact information, which do not affect your core rights), we will publish the revised Policy on the "Personal Center - About - Privacy Policy" page of this App, and the changes will take effect on the date of publication. Your continued use of this App after the changes shall be deemed as acceptance of such revised terms.
11.3 Reminder to Review Regularly
We recommend that you review this Privacy Policy regularly to learn about the latest privacy protection measures and the relevant rules for login, in-app purchases, and coins. Your continued use of this App after the revision of the Policy indicates that you have fully understood the meaning and legal consequences of all terms of the revised Policy and voluntarily accept its binding force on both parties.
12. Contact Us
If you have any questions, opinions or suggestions about this Privacy Policy, or need to exercise the rights stipulated in this Policy, or have any objections to the login function, in-app purchase function, or the use of coins (including the issuance of 50 free coins and the consumption of 5 coins per article), you may contact us through the following methods:
12.1 Contact Information
• Company Name: Yelfan Trading Limited
• Physical Address: Unit 21, 11/F, Tin Wai Industrial Building, 3 Hing Wong Street, Tuen Mun, Hong Kong
• Official Contact Email: wanghongkong6@gmail.com
12.2 Response Time
We will provide you with a formal written response within 15 working days after receiving your inquiry, request or suggestion; if the matter is complex and requires further verification and processing (such as in-app purchase disputes, abnormal coins, login issues, etc.), we will notify you of the progress in advance via email, and the overall maximum response time will not exceed 30 working days (in line with the requirements of major global data protection laws and regulations).
13. Other Terms
13.1 Relationship with the Te Hub User Agreement
This Privacy Policy is the core agreement between you and us regarding the protection of personal data, and together with the Te Hub User Agreement, constitutes a complete legal agreement governing your use of this App. The Te Hub User Agreement will further clarify the specific rules for the login function, in-app purchase function, and the use of coins (including detailed agreements on the issuance of 50 free coins and the consumption of 5 coins per work). If there is any conflict between the two agreements, with respect to matters related to personal data protection, this Privacy Policy shall prevail; with respect to other matters concerning your use of this App (such as login rules, in-app purchase rules, and coin rights and interests), the Te Hub User Agreement shall prevail.
13.2 Severability
If any term of this Privacy Policy is deemed by a competent judicial or administrative authority to be fully or partially invalid, illegal or unenforceable, it shall not affect the validity, legality and enforceability of the remaining terms, and the remaining terms shall still be performed strictly in accordance with the agreement.
13.3 Acceptance of Terms
Your act of checking to confirm your consent to this Privacy Policy and subsequent use of this App shall be deemed as your full and unconditional understanding of the meaning and legal consequences of all terms of this Policy, including the privacy protection agreements related to the login function, in-app purchase function, and the use of coins, and your voluntary acceptance of the binding force of this Policy on both parties.
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