Privacy Policy

Last updated: June 17, 2026 · Effective: June 17, 2026

1. Introduction

Bold Spirit, operated by Zunyi Han Yinghao Network Technology Co., Ltd., takes your privacy seriously. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit our website at boldspirit.mom or engage with our services.

2. Information We Collect

2.1 Information You Provide

We collect information you voluntarily provide when you submit inquiries, request proposals, or communicate with us. This includes your name, email address, phone number, company name, job title, and project-related information such as technical specifications, system requirements, and business objectives.

2.2 Information Collected Automatically

When you visit our website, we automatically collect certain information including pages visited, time spent on each page, navigation patterns, referring URLs, browser type and version, operating system, IP address, device type, and language preferences through cookies and similar technologies as described in Section 5.

2.3 Third-Party Information

We may receive information from business partners, analytics providers, and publicly available sources where permitted by applicable law. Any third-party data received is handled in accordance with this Privacy Policy.

3. How We Use Your Data

We process personal data for the following purposes: to respond to inquiries and provide requested services; to evaluate project requirements and prepare proposals; to communicate with you regarding service updates, technical bulletins, and relevant industry insights where you have consented; to analyze website usage and improve our services; to fulfill legal obligations, enforce agreements, and protect our rights; and to detect, prevent, and address technical issues, security incidents, or fraudulent activity.

4. Legal Basis for Processing (GDPR)

For individuals in the European Economic Area, we process data under the following lawful grounds: your consent for specific processing such as non-essential cookies or marketing communications; contractual necessity to fulfill agreements or take pre-contractual steps at your request; our legitimate interests in improving services, maintaining security, and communicating with clients, provided these do not override your fundamental rights; and legal obligations requiring us to process data to comply with applicable laws and regulations.

5. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to enhance functionality, analyze traffic, and improve user experience. Essential cookies are required for core site operation including session management and security. Analytics cookies help us understand how visitors interact with our site through aggregated, anonymous data. Preference cookies remember your settings for a personalized experience on return visits. You can manage cookie preferences through your browser settings. Disabling certain cookies may affect website functionality.

6. Data Sharing and Disclosure

We may share your data with trusted third-party service providers who assist us in operating our website and delivering services, under strict contractual obligations to protect your data. We may share information with professional advisors including legal and accounting professionals as necessary for business operations. In the event of a merger, acquisition, or sale of assets, your data may be transferred as part of the transaction with appropriate notification. We may also disclose information if required by law, legal process, or governmental request. We do not sell your personal data to third parties.

7. Data Retention

We retain personal data only as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. Retention periods consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use, the processing purposes, and applicable legal requirements. When data is no longer needed, we securely delete or anonymize it.

8. Data Security

We implement appropriate measures to protect your personal data including encryption of data in transit using TLS/SSL protocols, access-controlled server infrastructure with monitoring and regular security assessments, employee training on data protection practices, and incident response procedures to address potential data breaches promptly.

9. Your Rights

Under GDPR (EEA Residents): You have the right to access your personal data, request rectification of inaccurate or incomplete data, request erasure where there is no compelling reason for continued processing, request restriction of processing in certain circumstances, request data portability in a structured, commonly used format, object to processing based on legitimate interests or direct marketing, and not be subject to solely automated decisions that significantly affect you.

Under CCPA (California Residents): You have the right to know what personal information we collect about you, request deletion of your personal information subject to certain exceptions, opt out of the sale of your personal information (we do not sell personal information), and exercise your rights without receiving discriminatory treatment.

To exercise any of these rights, please contact us at support@boldspirit.mom. We will respond within the timeframes required by applicable law and may need to verify your identity before processing your request.

10. International Data Transfers

Your personal data may be transferred to, stored, and processed in countries other than your own, including China and the United States, where our servers and service providers are located. These countries may have data protection laws that differ from those in your jurisdiction. When we transfer data across borders, we implement appropriate safeguards including Standard Contractual Clauses approved by the European Commission and other lawful transfer mechanisms to ensure adequate protection.

11. Children's Privacy

Our services are not directed to individuals under the age of 16. We do not knowingly collect personal data from children. If you believe that a child has provided us with personal data without parental consent, please contact us immediately. We will take steps to delete such information promptly.

12. Third-Party Links

Our website may contain links to third-party websites, plugins, or services that are not operated by us. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party sites you visit.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. Changes are effective upon posting the updated policy on our website with an updated effective date. For significant changes, we may provide additional notice through our website or email.

14. Complaints

If you believe that our processing of your personal data violates applicable data protection laws, you have the right to lodge a complaint with your local data protection authority. We encourage you to contact us first so we can attempt to resolve your concerns directly. EEA residents may contact their country's supervisory authority. California residents may contact the California Attorney General's office.

15. Contact Information