Privacy Policy

01Introduction

Gracefuls — a computer systems design and related services practice developed by Gracefuls and operated under Suizhou RongJie Culture and Media Co., Ltd., located at No. 449 West Qingnian Road, Nanjiao Office, Zengdu District, Suizhou, 441300, China — respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you interact with our website at https://www.graceful.lat, when you contact us regarding our services, or when you otherwise engage with us in a professional capacity.

By accessing or using our website, submitting inquiries, or entering into a professional relationship with us, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree with any part of this policy, please discontinue use of our website and refrain from providing personal data to us.

We take your privacy seriously. All personal information is handled in accordance with applicable data protection laws, including but not limited to the General Data Protection Regulation (GDPR) where applicable, and the relevant privacy regulations of the People's Republic of China. This policy is designed to be transparent, thorough, and compliant with international standards for data privacy.

02Information We Collect

We collect several categories of information, depending on the nature of your interaction with Gracefuls. The types of data we may collect include:

Identity and contact data: Your full name, email address, telephone number, organization name, and professional title. We collect this when you submit a contact form, request information about our services, or enter into a client relationship with us.
Communication data: The content of messages you send through our contact forms, email correspondence, or other communication channels. This includes any project descriptions, technical requirements, or business objectives you share with us.
Technical and usage data: Internet Protocol (IP) address, browser type and version, operating system, referring URLs, time zone setting, pages visited, time spent on pages, and other diagnostic data collected automatically through standard web server logging and analytics tools.
Device data: Information about the device you use to access our website, including device type, screen resolution, and unique device identifiers where applicable. This data helps us optimize the user experience across different platforms.
Service engagement data: For clients with whom we have an active professional relationship, we may collect project-related information, service preferences, feedback on deliverables, and billing-related contact information. All such data is treated with the highest standard of confidentiality.

We do not knowingly collect sensitive personal data (such as racial or ethnic origin, political opinions, religious beliefs, health information, or biometric data) through our website or general business operations. If such data is inadvertently received, it will be promptly deleted or anonymized.

03How We Collect Information

We gather personal data through multiple channels, each designed to serve a legitimate business or operational purpose. Understanding how data reaches us helps you make informed decisions about what information you choose to share.

Direct interactions: The primary method through which we collect data is your direct, voluntary provision of information. This occurs when you fill out and submit our contact form on the website, send us an email at contact@graceful.lat, call our office at +15715828231, or correspond with us via any other communication medium. In each case, you control what data you provide, and we collect only the information necessary to respond to your inquiry or deliver our services.

Automated collection: As you navigate our website, certain technical information is automatically collected through standard internet protocols. Our web server logs record each visit, capturing the requesting IP address, the specific pages accessed, the timestamp of the request, the HTTP status code returned, and the amount of data transferred. We also use a minimal set of cookies and similar technologies to understand how visitors interact with our site.

Third-party sources: In limited circumstances, we may receive personal data about you from third parties, such as publicly available professional directories, business networking platforms where you have listed your contact information, or referral partners who connect us with potential clients. In all such cases, we verify the legitimacy of the data source and ensure that the data handling aligns with this policy.

04How We Use Your Information

Gracefuls uses your personal data exclusively for purposes that are necessary, legitimate, and clearly communicated. We do not sell, rent, or trade your personal information to any third party for marketing or commercial purposes. The specific purposes for which we process your data include:

Service delivery and client engagement: We use your contact and project-related data to communicate with you about our computer systems design and related services, prepare proposals and technical assessments, deliver agreed-upon services, and manage ongoing client relationships. This includes responding to inquiries, scheduling consultations, and providing technical documentation.
Website operation and improvement: Technical and usage data is analyzed to understand how visitors interact with our website, identify areas for improvement, diagnose technical issues, and ensure website security and performance. This analysis is performed at an aggregate level wherever possible.
Legal and regulatory compliance: We process data as necessary to comply with applicable legal obligations, including tax and accounting requirements, data protection regulations, and any lawful requests from government authorities with jurisdiction over our operations.
Business communications: With your consent where required, we may use your contact information to send you relevant updates about our services, industry insights, or information about events and developments that may interest you. You may opt out of such communications at any time.
Security and fraud prevention: We use technical data to monitor for and protect against unauthorized access, malicious activity, and potential security threats to our website and systems.

05Legal Basis for Processing

Under applicable data protection laws, including the GDPR where it applies, we rely on one or more of the following legal bases when processing your personal data:

Consent: Where you have given us clear, affirmative consent to process your personal data for a specific purpose. You have the right to withdraw your consent at any time by contacting us. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Contractual necessity: Where processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract. This includes processing necessary to deliver our computer systems design and consulting services.
Legitimate interests: Where processing is necessary for our legitimate business interests or those of a third party, provided those interests are not overridden by your fundamental rights and freedoms. This includes improving our website, maintaining security, and developing our service offerings.
Legal obligation: Where processing is necessary for compliance with a legal or regulatory obligation to which we are subject, such as financial record-keeping or responding to lawful requests from competent authorities.

We carefully evaluate each processing activity against these legal bases and document our assessments. If you have questions about the specific legal basis applicable to a particular processing activity, please contact us using the information provided below.

06Data Sharing and Disclosure

We share your personal data only in limited circumstances and always under strict conditions that protect your privacy. The categories of recipients with whom we may share data include:

Service providers: We engage trusted third-party companies and individuals to perform services on our behalf, such as website hosting, email delivery, analytics, and data storage. These service providers have access to your personal data only to the extent necessary to perform their functions and are contractually bound to process data exclusively in accordance with our instructions and applicable data protection laws.
Professional advisors: We may share data with our legal counsel, accountants, auditors, and insurance providers where necessary for the provision of professional advice or the protection of our legitimate business interests.
Business transfers: In the event of a merger, acquisition, reorganization, or sale of all or a portion of our assets, your personal data may be transferred as part of that transaction. We will provide notice on our website and, where feasible, direct notification to you of any such change in ownership or control.
Legal requirements: We may disclose your data if required to do so by law or in response to valid requests by public authorities, such as a court order, subpoena, or government agency demand. We will seek to notify you of such disclosures where permitted by law.

We do not, under any circumstances, sell your personal data to third parties. Any sharing of data beyond what is described in this section requires your explicit prior consent.

07International Data Transfers

Gracefuls is operated under Suizhou RongJie Culture and Media Co., Ltd., which is based in China. However, our website and certain third-party service providers may be hosted on servers located outside your country of residence, including in jurisdictions that may have data protection laws different from those in your home country.

When we transfer personal data across international borders, we implement appropriate safeguards to ensure that your data remains protected in accordance with this Privacy Policy and applicable law. These safeguards may include:

Transferring data only to recipients in countries that have been recognized as providing an adequate level of data protection by the relevant regulatory authorities;
Using standard contractual clauses approved by relevant data protection authorities, which impose contractual obligations on data recipients to protect your data;
Requiring our service providers to implement and maintain appropriate technical and organizational security measures as a condition of our engagement;
Conducting transfer impact assessments to evaluate and mitigate risks associated with cross-border data flows.

By using our website or services, you acknowledge that your data may be transferred to and processed in countries other than your country of residence. We remain responsible for the protection of your data regardless of where it is processed.

08Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. The specific retention period depends on the nature of the data and the purpose of its collection:

Inquiry and contact data: Data submitted through our contact forms or email inquiries is retained for up to twenty-four months after the conclusion of the relevant communication, unless a longer period is required by law or a contractual relationship is established.
Client relationship data: For clients with whom we have an active or recent professional relationship, we retain personal data for the duration of the relationship and for a period of seven years thereafter, consistent with applicable statutes of limitation and financial record-keeping requirements.
Technical and usage data: Server logs and analytics data are typically retained for up to twelve months. Aggregated, anonymized data may be retained indefinitely for analytical purposes.
Marketing communications: Where you have consented to receive marketing communications, we retain your contact information until you withdraw your consent or unsubscribe from our mailing list.

When personal data is no longer needed, we securely delete or anonymize it using industry-standard methods. If you wish to request earlier deletion of your data, please refer to the Your Rights section below.

09Data Security

Protecting the security of your personal data is a fundamental priority for Gracefuls. We implement and maintain a comprehensive set of technical, administrative, and physical security measures designed to safeguard your data against unauthorized access, alteration, disclosure, or destruction.

Our security measures include, but are not limited to: encrypted data transmission using Transport Layer Security (TLS) protocols for all website traffic and email communications; access controls that restrict data access to authorized personnel on a need-to-know basis; regular security audits and vulnerability assessments of our systems; network firewalls and intrusion detection systems; secure server infrastructure with physical access controls; and documented data handling procedures that our team members are trained to follow.

While we strive to use commercially acceptable means to protect your personal data, no method of transmission over the Internet or method of electronic storage is one hundred percent secure. We cannot guarantee the absolute security of your data, but we commit to promptly notifying you in the event of a data breach that poses a risk to your rights and freedoms, in accordance with applicable legal requirements.

You also have a role in protecting your data. We recommend that you use strong, unique passwords for your email and online accounts, keep your devices and software updated, and exercise caution when sharing personal information online.

10Your Rights and Choices

Depending on your jurisdiction and the applicable data protection laws, you may have one or more of the following rights regarding your personal data:

Right of access: You may request a copy of the personal data we hold about you and information about how it is being processed. We will provide this information within the timeframe prescribed by applicable law, generally within thirty days.
Right to rectification: If you believe that the personal data we hold about you is inaccurate or incomplete, you may request that we correct or supplement it. We encourage you to keep your information current so that we can serve you effectively.
Right to erasure (right to be forgotten): In certain circumstances, you may request that we delete your personal data. This right is not absolute and may be subject to legal obligations that require us to retain certain data.
Right to restrict processing: You may request that we limit the processing of your personal data in specific situations, such as while we verify the accuracy of contested data or assess a legitimate interest claim.
Right to data portability: Where processing is based on consent or a contract and is carried out by automated means, you may request that we provide your personal data in a structured, commonly used, and machine-readable format, and that we transmit it directly to another controller where technically feasible.
Right to object: You may object to the processing of your personal data based on our legitimate interests, including for direct marketing purposes. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests.
Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before the withdrawal.

To exercise any of these rights, please contact us using the information provided at the end of this policy. We will respond to your request within the applicable legal timeframe and may need to verify your identity before processing your request. If you are not satisfied with our response, you may have the right to lodge a complaint with your local data protection supervisory authority.

11Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyze site traffic, and understand where our visitors come from. A cookie is a small text file that is placed on your device when you visit a website. Cookies help websites remember information about your visit, such as your preferred language and other settings, which can make your next visit easier and the site more useful to you.

We use the following categories of cookies:

Essential cookies: These cookies are necessary for the website to function properly. They enable basic features such as page navigation, security, and access to secure areas of the website. The website cannot function properly without these cookies, and they cannot be disabled in our systems.
Analytics cookies: These cookies help us understand how visitors interact with our website by collecting and reporting information anonymously. We use this data to improve our web page architecture, content organization, and overall user experience. The analytics tools we employ aggregate data and do not identify individual users.
Functionality cookies: These cookies allow the website to remember choices you make, such as your language preference or the region you are in, and provide enhanced, more personalized features.

You can control and manage cookies through your browser settings. Most browsers allow you to refuse or accept cookies, delete existing cookies, and set preferences for how cookies are handled on a site-by-site basis. Please note that disabling certain cookies may affect the functionality of our website.

For users located in regions where consent is required for non-essential cookies, we will present a cookie consent banner on your first visit, allowing you to make informed choices about which cookies you accept.

12Children's Privacy

Our website and services are designed for a professional audience and are not directed to individuals under the age of eighteen. We do not knowingly collect personal data from children or minors. The computer systems design and consulting services we provide are intended solely for businesses, organizations, and adult professionals engaged in technology procurement and infrastructure planning.

If you are a parent or guardian and believe that your child has provided us with personal data without your consent, please contact us immediately using the information provided below. Upon notification, we will take prompt steps to delete such data from our records and terminate any associated accounts or communications.

If we become aware that we have inadvertently collected personal data from an individual under the age of eighteen without verifiable parental consent, we will take immediate action to remove that information from our servers and systems.

13Third-Party Services

Our website may contain links to third-party websites, platforms, or services that are not owned or controlled by Gracefuls. This Privacy Policy applies solely to information collected through our website and direct interactions with our team. We are not responsible for the privacy practices of third-party websites, applications, or services.

We encourage you to review the privacy policies of any third-party services you access through links on our website before providing any personal data. When you leave our website, we recommend that you read the privacy notice of every website you visit. We do not monitor, control, or endorse the information collection or privacy practices of third parties.

Some of the third-party services we may use in our operations include web hosting providers, email service platforms, and analytics tools. Each of these providers is contractually obligated to comply with data protection obligations consistent with this policy. A list of our key service providers is available upon request.

14Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or operational circumstances. When we make changes, we will revise the last updated date at the top of this page and, where the changes are material, we will provide a more prominent notice, such as a notification on our website homepage or a direct email to clients with whom we have an active relationship.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data. Your continued use of our website after any modifications to this policy constitutes your acknowledgment and acceptance of the updated terms to the extent permitted by applicable law.

Where changes to this policy require your consent under applicable data protection laws, we will seek such consent before implementing the changes, and your continued use will be subject to your affirmative acceptance of the updated policy.