Personal Information Protection and Privacy Policy

Hangzhou Ruitu Network Technology Co., Ltd. (hereinafter referred to as "we" or "Lumi") respects and protects the personal privacy and information security of all users (hereinafter referred to as "you") who use the "Lumi" App, Lumi Merchant App, Lumi web pages (user version and merchant version), WeChat Official Accounts, Mini Programs, and other "Lumi"-related platforms subsequently owned or operated by us (collectively referred to as the "Lumi Platform"). We attach great importance to the protection of user privacy and personal information. In view of this, we have formulated this "Lumi Privacy Policy" (hereinafter referred to as "this Policy") to confirm with you the matters related to Lumi's collection, storage, use, disclosure, and protection of your personal information during your use of the Lumi Platform services.

It should be particularly noted that this Policy does not apply to services provided to you by other third parties. Services provided by third parties are subject to their own privacy policies or similar policies explained to you. We do not assume any legal responsibility for any improper use or disclosure of information you provide by any third party.

Please read this Policy carefully, especially the terms marked in bold/bold underline, which you should focus on. Only start using the Lumi Platform after you have fully understood and agreed to it. If you/your guardian do not agree with any content of this Policy, you should immediately stop using it. When you start using the Lumi Platform, it means that you/your guardian have agreed that we may collect, store, use, share, and protect your personal information in accordance with this Policy. If you have any questions, opinions, or suggestions regarding the content of this Policy, you can contact us through the various contact methods provided in Section 11 of this Policy.

Table of Contents:

I. Definitions

1. Personal Information: Various information related to identified or identifiable natural persons recorded electronically or by other means, excluding anonymized information.

2. Sensitive Personal Information: Personal information that, once leaked or illegally used, may easily cause harm to the personal dignity of natural persons or endanger personal or property safety, including biometric information, religious beliefs, specific identities, medical health, financial accounts, whereabouts and轨迹 information, as well as personal information of minors under the age of fourteen. Sensitive personal information will be prompted in bold in this Policy.

3. De-identification: The process of processing personal information so that it cannot identify a specific natural person without the aid of additional information.

4. Anonymization: The process of processing personal information so that it cannot identify a specific natural person and cannot be restored.

5. Personal Information Deletion: The act of removing personal information from the systems involved in realizing daily business functions, making it irretrievable and inaccessible.

6. Lumi Platform: Refers to the "Lumi" App, "Lumi Merchant" App, Lumi web pages (individual user version and merchant user version), WeChat Official Accounts, Mini Programs, and other "Lumi"-related platforms subsequently owned or operated by us.

7. Affiliated Companies: Refers to companies or institutions that currently or in the future control Hangzhou Ruitu Network Technology Co., Ltd., are controlled by Hangzhou Ruitu Network Technology Co., Ltd., or are under common control with Hangzhou Ruitu Network Technology Co., Ltd.

II. How We Collect and Use Your Personal Information

You understand and agree that:

1. The business functions of the Lumi Platform are divided into basic functions and additional functions. We will explain in detail the personal information collected for each business function, the collection methods, purposes, and the impact of refusal to provide. Business functions specifically include:

1) Basic functions: including account creation, product browsing and transactions, order management, payment and logistics, and security assurance;

2) Additional functions: including real-name authentication, profile completion, user reviews, customer service, operational activities, information push, product sharing, information pre-filling, etc.

2. When you use our products/services, we need/may collect and use your personal information in the following two situations:

1) To realize the basic functions of providing our products and/or services to you, you must authorize us to collect and use the necessary information. If you refuse to provide the corresponding information, you will not be able to normally use our products and/or services;

2) To realize the additional functions of providing our products and/or services to you, you can choose to authorize us to collect and use the information. If you refuse to provide it, you will not be able to normally use the relevant additional functions or achieve the intended functional effects, but it will not affect your normal use of the basic functions of our products and/or services.

3)Although we need/may collect and use your personal information, the collected personal information is not used for personalized recommendations/targeted push purposes.

4. We may launch new or optimized functions from time to time, which may require the collection and use of new personal information or changes to the purpose or method of using personal information. In such cases, we will separately explain the purpose, scope, and method of collecting the corresponding information to you through updates to this Policy, pop-up windows, or page prompts, provide you with the opportunity to independently choose to agree, and continue collection and use only after obtaining your explicit consent.

5. For any collection and use of your personal information beyond the scope directly or reasonably related to the personal information collection and use scenarios disclosed in this section, we will inform you again and obtain your explicit consent.

(I) Basic Functions

1. Account Registration and Login

Before using the Lumi Platform services, you need to create an account on the Lumi Platform. The account types on the Lumi Platform include individual users, corporate employee users, and merchant users.

1) If you are an individual user, you may need to provide us with your mobile phone number, ID number, and set your user password on the Lumi Platform. You can also log in using a third-party platform account (such as Apple ID, Facebook, Google), and we will collect the unique identifier, avatar, nickname, and other information of the relevant account.

2) Enterprises can provide us with the enterprise name, address, contact person's name, email, and business license through the Lumi Enterprise official website to create an enterprise account.

3) If you are a corporate employee user, after your enterprise provides us with your name, department, and mobile phone number and adds you to the employee list, you may need to provide us with your mobile phone number and set your user password on the Lumi Platform to create a corporate employee account and use the corporate payment function.

4) If you are a merchant user, you may need to provide us with your mobile phone number and ID number, set your user password on the Lumi Platform, so that we can create a Lumi merchant account for you. To create a store within the merchant account, you may need to provide us with your store name, store type, store address, store contact phone number, photo of the store manager's ID card, store business license, and store front photo.

5) During the login process, for the security of your account, we will collect your running process information and the hardware serial number of the device you are using.

2. Mall and Transaction Services

1) Product Browsing and Ordering: When you browse products or place an order, we will collect your device information, operation logs, as well as the recipient's name, contact information, delivery address, etc. If you use location services to quickly fill in the address, we will request location permission.

2) Order Management: We will collect your order number, product information, order time, payment status, logistics information, recipient's name, contact information, delivery address, transaction price details, refund details, and invoice records so that you can query and delete order information on the Lumi Platform.

3. Transaction Payment

To help you successfully complete transactions and ensure your transaction security, we will collect your payment method, transaction amount, and payment status information. If you use third-party payment functions, we will also collect your payment account risk control information. If you use the Lumi wallet for payment, we will also record your balance, withdrawal records, Alipay account number, and bank card number information.

4. Security Assurance

To improve the Lumi Platform's monitoring of illegal and non-compliant behaviors, we will collect your log information, including browsing behavior, search records, and click records, IP address, and device information [including MAC address, device model, device unique identifier (IMEI, Android ID, IDFA, OAID), sensor information, operating system, system version, resolution, Wi-Fi information, telecom operator, SIM card information]. We will use browser web storage mechanisms and application data caches to collect information and store it locally on your device.

(II) Additional Functions

1. Customer Service Function: When you contact the Lumi customer service team, we will record your call information, your opinions or suggestions, and the name and contact information you provide through call recording and manual entry.

2. Real-Name Authentication Function: To meet legal and regulatory requirements and better protect user property safety, you can choose to provide your name and ID number.

3. Review Function: You can choose to evaluate products or services on the Lumi Platform anonymously. We will not collect your personal information during this process.

4. Profile Completion: You can choose to provide us with your avatar, gender, date of birth, industry, company, and occupation.

5. Operational Activities: When participating in operational activities, you may need to provide your name, photo, mailing address, contact information, and bank card number.

6. Information Push Function: Based on the mobile phone number you registered, we may provide you with order status, promotional activity, and other information through SMS or in-app notifications. You can unsubscribe by replying to the SMS prompt or closing it in the device settings.

(III) Device Permission Invocation

1. The Lumi Platform may invoke some of your device permissions. The following are the business functions corresponding to the invoked permissions, the purpose of our invocation, and the situation of asking you before invoking the permissions.

1) Android System Permission Invocation

Device PermissionPurpose of Invoking Device PermissionCan User Disable Permission
CameraUsed for taking photos in functions such as setting avatars, product photo reviews, and QR code scanning.Yes
LocationUsed to quickly locate your accurate position when filling in the delivery address.Yes
ContactsUsed to quickly select contacts when filling in the recipient.Yes
Access Phone IdentifierIdentify user identity to ensure transaction security.Yes
Phone StorageRead/write user information, logs, and cache product images.Yes
Network Status InformationObtain MAC address for network optimization and security verification.Yes
Enable Mobile Network/WLANConnect to the network.Yes
Floating Window/Foreground ServiceOrder progress notification and extending background survival.Yes
Accelerometer SensorIdentify screen orientation and optimize product display.Yes
ClipboardUsed to read the product links or order numbers you copy in intelligent recognition scenarios.Yes

2) iOS System Permission Invocation

Device PermissionPurpose of Invoking PermissionCan User Disable Permission
IDFAUsed for advertising effectiveness statistics and security assurance.Yes
CameraUsed for taking avatars, product review photos, etc.Yes
ContactsQuickly select recipient.Yes
LocationQuickly locate delivery address.Yes
MicrophoneVoice search for products or contact customer service.Yes
Photo Album Read/SaveUpload avatars, save product images.Yes
NotificationsSend order and promotional messages.Yes
BluetoothAssist indoor positioning.Yes

(IV) Exceptions to Obtaining Authorized Consent

You fully understand and agree that we may collect and use your personal information without your authorized consent in the following circumstances:

1. Necessary for the conclusion or performance of a contract to which the individual is a party;

2. Necessary for performing statutory duties or obligations;

3. Necessary for responding to public health emergencies or protecting the life, health, and property safety of natural persons in emergency situations;

4. Processing personal information within a reasonable scope for public interest purposes such as news reporting and public opinion supervision;

5. Processing personal information that the individual has disclosed themselves or that has been lawfully disclosed within a reasonable scope in accordance with the provisions of the Personal Information Protection Law;

6. Other circumstances provided for by laws and administrative regulations.

III. How We Use Cookies and Similar Technologies

1. Cookies are a mechanism that supports the server side in storing and retrieving information on the client side. When you use Lumi products or services, to provide you with a relaxed and secure access experience, we may use cookies or similar technologies to collect and store information to understand your preferences, improve product services and user experience, or promptly detect and prevent security risks. You can clear all cookies saved in the software.

2. Our platform may also contain some electronic images (web beacons) used to calculate users browsing web pages or accessing certain cookies. We will collect information about your web browsing activities, such as IP address, browser type, operating system, etc.

IV. How We Store Your Personal Information

1. Personal Information Retention Period

1) During the user's use of the Lumi Platform services, we will continuously retain the user's personal information within a reasonably necessary scope.

2) When you independently delete your personal information or cancel your account, we will retain your existing personal information for the shortest period required by laws and regulations. When your personal information exceeds the above retention period, we will anonymize it.

2. Personal Information Storage Location

1) The personal information we collect about you will be stored and used in the place of use;

2) If it involves the transmission of personal information overseas, we will clearly inform you of the purpose of the overseas transfer, the recipient, security safeguard measures, and other circumstances, and separately obtain your consent.

V. How We Protect Your Personal Information

1. Security Protection Measures

The company will adopt strict security systems and industry-standard security technologies and procedures to ensure that your personal information is not lost, leaked, damaged, or subject to unauthorized access or use. User personal information is encrypted and stored on servers, with data isolation technology used for storage; data transmission uses encrypted transmission protocols.

2. Security Incident Handling

Once a security incident occurs, we will promptly inform you of the basic situation and risks of the incident, the measures we have taken or will take, and suggestions on how you can reduce the risk yourself.

VI. How We Use Scheduling Algorithms

1. Algorithm Name

We use the Lumi Mall Recommendation and Logistics Scheduling Algorithm. To make you more clearly aware of the relevant scheduling methods to protect your right to know and choose, we provide you with the following specific information:

Algorithm NameMall Recommendation and Logistics Scheduling Algorithm
Basic Principle of the AlgorithmBased on user orders, product inventory, and logistics capabilities, it comprehensively calculates matching weights to allocate the optimal shipping warehouse or store for users and display related product recommendations.
Algorithm Operation MechanismWhen a user places an order, the matching degree is calculated based on dimensions such as delivery address, inventory distance, and logistics timeliness to find the optimal shipping solution; non-personalized display sorting is performed based on product popularity.
Algorithm Application ScenariosOrder allocation and product display scenarios on the Lumi App, Merchant App, and web pages.
Algorithm Purpose and IntentImprove order fulfillment efficiency and optimize the user shopping experience.

VII. How We Share, Transfer, and Publicly Disclose Your Personal Information

1. Sharing

We may occasionally share some personal information with affiliated companies and strategic partners who cooperate with us to provide products and services, in order to provide the products or services you require.

1) Sharing with Affiliated Companies: To improve the quality of our products and services, we may share your personal information with our affiliated companies.

2) Sharing with Authorized Partners: We may share your necessary personal information with payment service providers, logistics service providers, etc.

3) Sharing with Third-Party SDK Service Providers

We will share some of your personal information with third-party SDK service providers through the Lumi Platform to facilitate your use of certain functions of the Lumi Platform. The details are as follows:

Function NameSDK NamePurpose of UseThird Party NameTypes of Personal Information CollectedThird-Party Privacy Policy Link
MapBaidu MapsPositioning, address resolutionBeijing Baidu Netcom Science Technology Co., Ltd.Device identification information, location information, etc.Link
PaymentWeChat PayPaymentTenpay Payment Technology Co., Ltd.Device informationLink
PaymentAlipayPaymentAlipay (Hangzhou) Information Technology Co., Ltd.IMEI, IMSI, MAC address, etc.Link
PushGetuiPush messagesZhejiang Daily Interactive Network Technology Co., Ltd.Device identifier, application list, etc.Link
StatisticsUmengStatistics, sharingUmeng Tongxin (Beijing) Technology Co., Ltd.Unique device identifier, location informationLink
Apple LoginSign in with AppleApple ID loginApple Inc.User identifier, name, emailLink
Facebook LoginFacebook SDKFacebook account loginMeta Platforms, Inc.Public profile, emailLink
Google LoginGoogle Sign-InGoogle account loginGoogle LLCGoogle account ID, emailLink

2. Transfer

Unless we obtain your explicit consent, we will not transfer your personal information to any company, organization, or individual. However, in circumstances such as mergers, divisions, bankruptcy liquidation, etc., we will require the recipient to continue to be bound by this Policy.

3. Public Disclosure

We will only publicly disclose your personal information with your explicit consent, as required by law, or based on situations such as user dispute resolution.

VIII. Your Rights in Personal Information Processing Activities

1. Access Personal Information: You can access information such as your avatar and orders in the "Personal Center" of the Lumi App.

2. Correct Personal Information: You can modify your personal data in the account settings.

3. Delete Personal Information: You can submit a deletion request through customer service.

4. Withdraw Consent: You can disable permissions through device settings or unsubscribe from commercial information as prompted by SMS.

5. Cancel Account: You can cancel your account through the settings function of the Lumi Platform.

IX. How We Protect Minors' Personal Information

We attach great importance to the protection of minors' information. If you are a minor under the age of 18, your guardian needs to carefully read this Policy and authorize you to agree to use the Lumi Platform in accordance with this Policy. If we discover that a minor has registered without the guardian's consent, we will try to delete the relevant personal information as soon as possible.

X. How We Update the Privacy Policy

If there are changes in the business functions of the Lumi Platform, we will promptly revise this Policy and publish the latest version on the platform, notifying users through push notifications. Without your explicit consent, we will not reduce the rights you enjoy under this Policy.

XI. How to Contact Us

Hangzhou Ruitu Network Technology Co., Ltd.

1) You can contact us through the "Online Customer Service" within the Lumi App;

2) Complaint/Report Email: 994010986@qq.com;

We will verify and process the information you provide within 15 days. If you are not satisfied with our response, especially if you believe that our personal information processing has harmed your legitimate rights and interests, you can seek a solution by filing a lawsuit with a competent court in the defendant's domicile.

© Hangzhou Ruitu Network Technology Co., Ltd.