Shenzhen Tulu Technology Co., Ltd. ("TULU Tech", "we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal data when you visit our website and use our services.

1. Information We Collect

When you submit information through our contact form, we collect:

• Name — to identify you and provide personalized service
• Email address — to communicate with you and provide timing service support
• Company name — to understand your organization and offer tailored solutions
• Other information you voluntarily submit — such as event requirements

When you use our Event Management System (event.tulu360.cn), we may collect additional data necessary for event operations.

2. How We Use Your Information

We use the collected information for the following purposes:

• Respond to your inquiries and provide event timing solutions
• Deliver customer support and technical services
• Improve our products and service quality
• Comply with applicable legal and regulatory obligations

3. Legal Basis (for EEA Users)

If you are located in the European Economic Area (EEA), our legal bases for processing your personal data are:

• Consent — when you submit our contact form, you explicitly consent to the processing of your information
• Contractual necessity — to enter into or perform a contract for event timing services
• Legitimate interests — improving our services, maintaining website security, and other legitimate business interests

4. Data Storage and Security

Your personal data is stored on secure servers operated by Alibaba Cloud, located in China. We implement reasonable technical and organizational measures to protect your data, including encrypted transmission (HTTPS), access controls, and regular security reviews.

International Data Transfers: Our servers are located in China. If you are located in the EEA or other regions, your data will be transferred to China. We ensure such transfers are lawful through Standard Contractual Clauses (SCCs) or your explicit consent.

5. Data Retention

We retain your personal data for:

• The duration of our business relationship, plus
• 1 year after the end of our business relationship (for compliance and potential legal claims)
• Longer if required by applicable law

After the retention period, we will securely delete or anonymize your personal data.

6. Your Rights

Under applicable data protection laws (including the GDPR), you have the following rights:

• Right of access — obtain a copy of your personal data held by us
• Right to rectification — request correction of inaccurate personal data
• Right to erasure (Right to be forgotten) — request deletion of your personal data
• Right to restriction of processing — request limited processing in certain circumstances
• Right to data portability — receive your data in a structured, commonly used format
• Right to object — object to processing based on legitimate interests
• Right to withdraw consent — withdraw consent at any time without affecting the lawfulness of processing before withdrawal

To exercise any of these rights, please contact us using the details below. We will respond within 30 days.

7. Cookies

Our website currently uses only essential functional cookies (e.g., for language preference). We do not use any third-party tracking or advertising cookies. If we implement analytics cookies in the future, we will notify you and obtain your consent in advance.

You can manage and delete cookies through your browser settings.

8. Third-Party Services

We use the following third-party service providers:

• Alibaba Cloud — server hosting, image storage (OSS), CDN
• MySQL — database storage

These providers access your data only to the extent necessary and are contractually obligated to comply with data protection requirements.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be posted on this page with an updated "Effective Date" at the top.

10. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact us:

• Email: service@tulu360.cn
• Company: Shenzhen Tulu Technology Co., Ltd.
• Address: Shenzhen, Guangdong, China (please request via email for full address)

If you are not satisfied with our response, particularly if you believe we have processed your data unlawfully, you have the right to lodge a complaint with your local data protection supervisory authority.