Last updated: [Date]
Privacy Policy
Who this notice covers
This notice describes how 吕城澔 ("we") handles personal data when you use the Content Factory Agent website and product, including the public pages at /en and the legal pages, the sign-in product, and demo requests.
It is a draft for counsel. It is not a promise that every practice below is already switched on. Where a fact is unknown, it is in brackets.
Draft, pending attorney review. Do not treat this page as signed legal advice or as the final notice.
Who we are
The operator of this website (主办单位) is 吕城澔. The website ICP filing number is 粤ICP备2026018121号-1. The filing is a personal, non-commercial filing. This draft does not state a company name, a registered address, a company number, or a VAT number.
Privacy contact: landaitrading@outlook.com. Data protection officer: [DPO — not named in this draft]. EU / UK representative under Article 27: [EU/UK representative — pending legal review].
Data we collect
What we actually collect depends on whether you only read these public pages, email us, or sign in.
- Account data, after an account is created for you: username, role, and a password stored in hashed form. The public landing page does not ask you to register.
- Content you submit once signed in: briefs, reference notes, drafts, image and video prompts, and files you upload.
- Publish records: the platform, the draft, and the notes a person types when they register a publish.
- Demo and support messages: whatever you send to landaitrading@outlook.com or through the demo link, plus the address you write from.
- Session data after sign-in: the cf_session cookie, and a server-side session record that stores IP address and user agent. See the cookie notice.
- Technical logs: public pages and the product may be recorded by the host in request logs (IP address, user agent, time, URL). Exact fields and retention: [log fields] and [log retention].
- Payment data: none is collected on these public pages. If billing is added, this notice will name the processor. [Payment data — not collected here today].
Why we use it
- To run the product: sign-in, drafting, the compliance check, export, and publish registration.
- To answer a demo request or a support email.
- To keep the service reliable and secure, including diagnosing faults.
- To meet a legal obligation if one applies. Which obligations: [legal obligations — pending legal review].
- We do not use the public landing page to build an advertising profile of you. If that changes, this notice and the cookie notice change first.
Legal bases (GDPR and UK GDPR)
For people in the EEA or the UK, counsel still has to confirm the basis for each purpose. The draft mapping is:
- Contract (Article 6(1)(b)): providing the signed-in product you or your organisation asked for.
- Legitimate interests (Article 6(1)(f)): securing the service, keeping basic logs, and answering an unsolicited demo email. The interest and the balancing test: [legitimate-interests assessment — not written yet].
- Consent (Article 6(1)(a)): any non-essential cookie or similar tech, if we ever set one. None is documented for the public pages today.
- Legal obligation (Article 6(1)(c)): [obligations — pending legal review].
If the operator is established in China, or the Personal Information Protection Law otherwise applies, the rights in that law (including access, copy, correction, and deletion) sit alongside the GDPR rights for the people they cover. The governing analysis is [applicable law — pending legal review].
California residents
If you are a California resident, the CCPA / CPRA may give you the right to know, delete, correct, and opt out of sale or sharing of personal information, and to limit use of sensitive personal information. Appeal rights and authorised-agent rules also need counsel.
[Whether personal information is sold or shared — pending legal review]. Do not read this draft as a "we do not sell" promise. [Sensitive personal information — pending legal review]. Send requests to landaitrading@outlook.com.
Processors and sub-processors
Vendors who process personal data for us will be listed here. Every row below is a placeholder. Do not launch with an unnamed vendor.
| Processor | Purpose | Location | Status |
|---|---|---|---|
| [AI model provider] | Drafting from briefs and prompts | [region] | Placeholder — name the vendor |
| [Hosting provider] | Application and database hosting | [region] | Placeholder — name the vendor |
| [Email provider] | Demo and support mail | [region] | Placeholder — may be unused |
| [Analytics provider] | Site measurement | [region] | Not confirmed. Do not add a tag until this row is real. |
Cross-border transfers
Personal data may be processed where the operator and the processors above are located. Those regions are [processor regions — pending legal review]. Hosting region: [Hosting region].
For EEA or UK personal data, the transfer tool (for example EU Standard Contractual Clauses, the UK IDTA or Addendum, or another lawful mechanism) is [transfer mechanism — pending legal review]. This draft does not claim that clauses are signed.
If Chinese cross-border rules apply (security assessment, standard contract, or certification), the mechanism is [China export mechanism — pending legal review].
Retention
We keep personal data only as long as the purpose, the contract, or the law requires. The periods are not set in this draft:
- Account and content data: [retention period], then delete or anonymise.
- Demo and support email: [retention period].
- Server logs: [log retention].
- Session records: for the life of the session (8 hours, or 30 days if the person chose "remember me" at sign-in), and [session-record retention] after that.
- Backups: [backup retention].
Your rights, including deletion
Depending on where you live, you may have the right to access, correct, delete, restrict, or receive a copy of your personal data, to object to certain processing, to withdraw consent, and to lodge a complaint with a supervisory authority.
To ask for deletion or any other request, email landaitrading@outlook.com with the subject "Privacy request" and enough detail for us to find the account. We will answer within [response window — pending legal review, often 30 days or one calendar month]. We may need to confirm it is you.
EEA lead supervisory authority: [supervisory authority]. UK: the Information Commissioner’s Office, unless counsel names another route. China: [China enforcement contact — pending legal review].
You can also ask for a human look at a decision that is solely automated, if one ever has a legal or similarly significant effect. Drafting assistance in this product is reviewed by a person before publish. [Automated decision-making — pending legal review].
Children
The service is not directed at children. The draft age threshold is under 16 in the EEA (a Member State may set a lower age, not below 13) and under 13 in the UK. Confirm [minimum age] before publication.
We do not knowingly collect personal data from children. If you believe a child has provided data, email landaitrading@outlook.com and we will delete it, subject to [deletion process].
Security
The product uses access control, stores the session cookie as httpOnly, and the production site is served over HTTPS. Certifications such as SOC 2 or ISO 27001: [none claimed]. Encryption at rest: [encryption at rest — pending review]. No method of transmission or storage is perfectly secure.
Changes
We will update this page when the practices change and replace [Date]. If a change is material, the extra step (email, in-product notice, or both) is [change notice — pending legal review]. The previous version will be [archive location — not set].
Contact
Email landaitrading@outlook.com. Demo requests use the same address. This draft does not state a postal address.
Please do not send passwords or full identification documents in a first email.