Dao Le Me Privacy Policy

Last updated: July 9, 2026 Effective date: July 16, 2026 Version: 2.0

Important notice (please read first)

Dao Le Me ( “we”, “us”, “our”, or the “App” ) is a self-management health-habit tracking and support application offering logging, statistics, meditation audio, community interaction, reminders, device pairing, and related features.

This Privacy Policy (the “Policy”) explains how we collect, use, store, share, transfer across borders, and protect your personal information, and the rights you have under law.

Special reminders:

1. The Service may process data related to your behavior habits, mood/energy self-ratings, and impulse/release logs. In some jurisdictions such data may be sensitive personal information / special-category data / health-related information. We process it only as needed for core features and apply stricter protections.
2. The Service is not a medical device and does not provide diagnosis, treatment, or prescriptions; statistics and prompts are for self-management reference only.
3. The Service is primarily for adults aged 18+. We do not intentionally market to children.
4. Before use, carefully read this Policy and the Dao Le Me Terms of Service. If you disagree, stop registering, logging in, or using the Service.
5. This document is a product compliance template and does not replace professional legal advice. Before public release, have qualified counsel review it against your entity, server locations, SDKs, and actual processing.

Questions: see “How to contact us”.

Table of contents

1. Definitions and scope
2. Categories of personal information we process
3. Purposes, legal bases, and necessity
4. Cookies and local storage
5. Device permissions
6. Sharing, processors, transfer, and public disclosure
7. Cross-border transfers
8. Storage location, retention, and security
9. Your rights (China / EU / US common rights)
10. Automated decision-making and personalization
11. Minors
12. Third-party services and SDKs
13. Updates to this Policy
14. How to contact us
15. Governing law and dispute resolution

1. Definitions and scope

1.1 Definitions

1.2 Scope

This Policy applies to personal information processing when you use the Service via official clients, the website, or other entrances we recognize. It does not apply to third-party websites, third-party apps, or independent privacy policies of third-party community publishers (review those separately).

1.3 Controller identity

Under applicable law, the Dao Le Me operator is the controller / processor of your personal information (terminology varies by jurisdiction). For legal entity name, registered address, unified social credit code, or DPO details, request the latest entity information page by email.

Public contact email: dlm-support@jituiadmin.click

2. Categories of personal information we process

We follow principles of lawfulness, fairness, necessity, good faith, and data minimization. Bold items below are typically required for core features; others are optional or collected only when you enable related features.

2.1 Account and identity

• Username and password (passwords stored with irreversible or industry-standard protection)
• User ID and login credentials (e.g. session tokens / JWT)
• Optional: nickname, avatar, bio
• Optional: language preference, dark mode, app-lock settings (including local PIN configuration; PINs are not uploaded or are handled only in protected form, depending on implementation)

2.2 Health-habit and status information (may be sensitive)

When you use logging, stats, achievements, etc., we may process:

• Log type (e.g. impulse, release/relapse categories you submit)
• Time, frequency, notes, triggers, and other content you enter
• Energy, mood, or other self-rating scores or tags
• Derived streaks, status scores, trends, goal progress, XP, levels, achievements
• Aggregate statistics used for risk tips or predictive displays (if any)

We do not proactively require medical records, prescriptions, genetic data, or clinical diagnosis reports. Do not put others’ private data or highly sensitive unrelated information in notes.

2.3 Community and social

• Posts, comments, likes, favorites, topics, and ranking interactions
• Friend relationships, friend requests, invite-code use (if any)
• Profile information you choose to publish; search history (if any)
• Report, block, and other safety-moderation actions

Content you publish publicly may be viewed, shared, or quoted by others—post carefully.

2.4 Content consumption

• Meditation/audio progress, duration, playlists, and favorites
• Article reading records and browsing history

2.5 Messages, reminders, and notifications

• In-app messages, system notices, and read status
• Reminder times, recurrence, and toggles you set
• Device push identifiers needed for delivery (e.g. system push token after you allow notifications)

2.6 Device, logs, and security

To keep the Service secure and stable, we may automatically collect:

• Device model, OS version, App version, language, and time zone
• Device identifiers (within lawful and necessary scope, e.g. risk control, anti-abuse, device management)
• IP address, network type, request time, API access logs
• Crash logs and performance diagnostics
• Login device lists and abnormal-login detection data

2.7 Watch / paired devices (if used)

• Pairing status, device name/model-type identifiers, authorization and unbind records
• Temporary codes or session data needed to complete pairing

2.8 Information we do not proactively collect

• Precise location (unless a future feature clearly requests and you authorize it)
• Contacts, SMS, call logs
• National ID, bank card numbers, or biometric templates you did not provide (system face/fingerprint unlock is handled by the OS; we generally cannot read raw biometric templates)

3. Purposes, legal bases, and necessity

3.1 Main purposes

3.2 Legal bases (as applicable where you live)

Depending on jurisdiction, we may process personal information based on one or more of:

1. Contract performance / providing the Service you request (e.g. account, log sync)
2. Consent (especially sensitive data, push notifications, optional profiling)
3. Legal obligation (e.g. regulatory requirements, retaining certain logs)
4. Legitimate interests (e.g. security, abuse prevention; balanced against your rights)
5. Vital interests (emergencies, where law allows)

In the People’s Republic of China, we primarily rely on the Personal Information Protection Law, Cybersecurity Law, Data Security Law, and similar rules, using notice-and-consent, contract necessity, legal obligations, and other lawful bases; for sensitive personal information we obtain separate consent or rely on other statutory exceptions.

In the EEA / UK / Switzerland, we rely on GDPR / UK GDPR bases; special-category data is processed only with explicit consent or other lawful exceptions.

In California and other US states, we disclose business purposes, rights, and “sale/share” practices as required (see §9.3).

4. Cookies and local storage

We may use:

• Local storage (e.g. SharedPreferences, secure storage, cache) for login state, theme, language, drafts, etc.
• Cookie-like technologies (if any web surfaces exist) for sessions and preferences

Uses: stay signed in, security, preferences, performance. You may clear App data/cache in system settings; you may need to log in again and some local preferences may be lost.

We do not use local storage to sell your habit logs to third-party ad networks.

5. Device permissions

Permission prompts explain purpose when the feature is used. You can revoke permissions anytime in system settings.

6. Sharing, processors, transfer, and public disclosure

6.1 General principles

We do not sell your personal information. We share only what is necessary for the purposes in this Policy and require recipients to protect data at least as well as this Policy requires.

6.2 Possible sharing / processing scenarios

1. With your consent or at your direction (e.g. public profile, community posts)
2. Service providers / processors: cloud hosting, object storage, push, email, crash analytics, CDN, etc. (only as needed to run the Service)
3. Affiliates: to provide the Service under purpose limitation and security requirements
4. Legal requirements: lawful requests from courts or regulators
5. Emergencies: protecting your or others’ vital interests

6.3 Transfer

In mergers, acquisitions, reorganizations, or bankruptcy, if personal information is transferred, we will require the successor to honor this Policy or obtain new authorization where required by law.

6.4 Public disclosure

Except with your clear consent or legal mandate, we do not publicly disclose your personal information, other than content you voluntarily post in the community.

6.5 De-identification and anonymization

We may use de-identified or aggregated data to improve the product; fully anonymized data may no longer be subject to personal information obligations under applicable law.

7. Cross-border transfers

7.1 Default storage

Personal information collected and generated in the People’s Republic of China is in principle stored in mainland China.

7.2 If cross-border transfer occurs

If cloud services, global collaboration, or your cross-border use require providing personal information overseas, we will:

1. inform you of overseas recipient identity/contact, purposes, means, categories, and how to exercise rights (when required by law);
2. obtain separate consent or other lawful bases as required;
3. use SCCs, certification, security assessments, or other applicable safeguards;
4. transfer only the minimum data needed.

EEA/UK users: transfers follow GDPR Chapter V mechanisms (adequacy, SCCs, etc.).

8. Storage location, retention, and security

8.1 Retention

We keep personal information only as long as needed for the purposes, for example:

After the period ends we delete or anonymize, unless law requires otherwise.

8.2 Security measures

We take reasonable technical and organizational measures, including:

• transport encryption (e.g. TLS)
• access control, least privilege, audit logs
• password and credential protection
• secure development lifecycle and vulnerability response
• employee confidentiality and permission management
• incident response plans; timely notice to you and regulators when required if an incident may harm your rights

Note: no measure is absolutely secure. Protect your password, enable optional app lock, and avoid staying logged in on shared devices.

9. Your rights

To the extent applicable law allows, you may exercise the following rights via in-app features or email:

9.1 General rights

1. To be informed and to decide: understand processing rules; choose whether to consent
2. Access / copy: obtain a copy of your personal information
3. Correction / completion: correct inaccurate or incomplete information
4. Deletion: request deletion where legal grounds apply
5. Withdraw consent: without affecting processing based on consent before withdrawal
6. Delete account: stop the Service and delete or anonymize as required by law
7. Explanation: request explanation of processing rules
8. Complaint: complain to a competent authority

9.2 Additional rights in EU / UK and similar regions (if applicable)

• Restriction of processing
• Data portability
• Object to processing based on legitimate interests
• Object to direct marketing
• Not be subject to decisions based solely on automated processing (including profiling) that produce legal or similarly significant effects (we do not currently make such solely automated decisions with major legal effects)
• Lodge a complaint with a supervisory authority

We respond to valid requests as soon as possible and usually within 30 days (extensions allowed by law for complex cases, with reasons).

9.3 US state rights (e.g. California) (if applicable)

California residents may have rights to:

• know categories of personal information collected and business purposes
• delete and correct
• opt out of “sale” or “sharing” of personal information (we do not sell personal information as a business; if future “sharing” for cross-context behavioral advertising exists, we will provide an opt-out)
• exercise privacy rights without discrimination

How to request: email dlm-support@jituiadmin.click with subject “Privacy Request”, stating request type and verifiable identity information.

9.4 China-specific notes

Under the PIPL you may access, copy, correct, delete, withdraw consent, and delete accounts, among other rights. For sensitive personal information we fulfill separate consent and impact-notice duties (except statutory exceptions). We process requests within 15 working days (or other statutory timelines).

9.5 Limits

We may lawfully be unable to fully fulfill requests involving national security, public security, litigation evidence, others’ legitimate rights, or technical infeasibility. We will explain reasons.

10. Automated decision-making and personalization

We may use rules or models to produce:

• statistical displays such as status scores, trends, and goal completion
• content ranking or recommendation lists (if any)

These usually improve experience and do not constitute automated decisions with legal or similarly significant effects. You may reduce use of related features, adjust settings, or contact us to limit non-essential personalization.

11. Minors

1. The Service is primarily for adults 18+.
2. We do not knowingly collect personal information from children under 13 (or a higher age threshold where you live, e.g. 16).
3. If you are a minor, read this Policy with a guardian and use only with guardian consent.
4. If we learn we collected children’s information without valid consent, we will delete it promptly.
5. Guardians exercising rights should email us with reasonable proof of guardianship.

Areas with adult-oriented or sensitive community content (if any) are for adults only; do not help minors bypass restrictions.

12. Third-party services and SDKs

To provide push, crash analytics, cloud storage, etc., we may integrate third-party SDKs or services. We will:

• integrate only what is needed for functionality
• require security and data-processing commitments
• update in-app notices, this Policy, or a third-party list when the inventory changes

Principle: your detailed health-habit records are not provided to ad platforms for cross-app ad tracking.

Request the latest third-party SDK list (name, purpose, fields, privacy links) by email.

13. Updates to this Policy

We may revise this Policy from time to time. For material changes we will notify you via prominent in-app notice, dialog, or inbox message, and update the date and version at the top.

Material changes include, without limitation:

• major changes to purposes, means, or categories of personal information
• major changes to controller identity or organization
• major changes to main sharing/cross-border recipients
• major changes to your rights or how to exercise them

If renewed consent is required, we will seek it before you continue use. Historical versions may be requested from us.

14. How to contact us

• Email: dlm-support@jituiadmin.click
• Suggested subjects:
  • “Privacy rights request”
  • “Data deletion / account deletion”
  • “Security incident report”

We respond within applicable statutory timelines (commonly 15 working days in mainland China; 30 days under GDPR, with lawful extensions).

If unsatisfied with our response, you may complain to a competent personal information / data protection authority where you live.

15. Governing law and dispute resolution

1. Formation, validity, interpretation, and dispute resolution under this Policy are primarily governed by the laws of the People’s Republic of China (for this Policy, excluding Hong Kong, Macao, and Taiwan law), except where mandatory consumer or data-protection rules provide otherwise (e.g. non-waivable rights of EEA users).
2. Disputes should first be negotiated amicably; failing that, either party may sue in a people’s court with jurisdiction at our domicile, unless mandatory jurisdiction rules apply.
3. If this Policy conflicts with the Dao Le Me Terms of Service, personal information protection matters are governed by this Policy.
4. Invalidity of part of this Policy does not affect the remainder.

Appendix A: Personal information collection list (summary)

Appendix B: Sensitive personal information processing (summary)

Dao Le Me Team Version 2.0 · July 9, 2026