1. Who We Are
QINGHE is operated by:
KANG FU LIN LIMITED
Privacy inquiries may be sent to:
payments@qinghewell.com
Where applicable, the entity identified above acts as the controller, business, regulated entity, or personal information processor responsible for your personal information under applicable privacy law.
2. Scope of This Policy
This Privacy Policy applies to personal information processed through QINGHE's websites and services.
It does not apply to third-party websites, platforms, payment providers, or services that operate under their own privacy policies.
QINGHE is a general wellness and educational service and is not a healthcare provider. Our services are not intended to create a doctor-patient or other healthcare-provider relationship.
3. Personal Information We Collect
Depending on how you use QINGHE, we may collect the following categories of information.
Information You Provide Directly
This may include:
- email address;
- name, if voluntarily provided;
- country or region;
- customer-support communications;
- order and purchase information;
- information submitted when requesting access, correction, or deletion;
- feedback or survey responses; and
- other information you choose to provide.
Assessment and Wellness Information
When you complete a QINGHE assessment, you may provide information concerning everyday experiences such as energy, sleep, digestion, temperature preferences, skin, mood, environmental sensitivity, and other wellness-related characteristics.
QINGHE may use these responses to calculate constitution scores, identify primary or secondary constitution tendencies, and generate your report.
Because this information may reveal or allow inferences concerning your physical or mental wellbeing, we treat it with heightened care.
Please review our separate Consumer Health Data Privacy Policy for more information.
Transaction Information
If you purchase a digital report, we may receive transaction-related information such as:
- order identifier;
- payment status;
- transaction date;
- amount and currency;
- refund status; and
- limited information supplied by the payment provider.
Unless expressly stated otherwise at checkout, payment card or banking credentials are collected and processed directly by the applicable payment service provider rather than stored by QINGHE.
Technical and Usage Information
When you access our services, we may automatically receive information such as:
- IP address;
- device type;
- browser type and version;
- operating system;
- language;
- approximate region derived from IP address;
- referring page;
- pages viewed;
- timestamps;
- diagnostic and error information; and
- security and fraud-prevention signals.
Cookies and Similar Technologies
We may use cookies, local storage, pixels, or similar technologies for functions such as:
- keeping the website operational;
- remembering preferences;
- measuring website performance;
- preventing abuse;
- understanding general usage; and
- where permitted and enabled, measuring advertising effectiveness.
Where applicable law requires consent, non-essential cookies and similar technologies will not be activated until the required consent has been obtained.
More information will be provided through our Cookie Preferences interface and, where applicable, our Cookie Policy.
4. How We Use Personal Information
We may process personal information to:
Provide the Service
Including to:
- operate the website;
- administer the assessment;
- calculate assessment results;
- generate reports;
- process purchases;
- deliver purchased content;
- restore access where available; and
- respond to customer requests.
Maintain Security and Prevent Abuse
Including to:
- detect misuse;
- prevent fraud;
- protect accounts and transactions;
- investigate technical problems;
- maintain system integrity; and
- protect QINGHE, our users, and others.
Improve the Service
We may use appropriately minimized, aggregated, or deidentified information to understand service performance, troubleshoot problems, improve usability, and evaluate product features.
Where possible, product analytics should not include the contents of individual assessment answers or individual constitution results.
Communicate With You
We may send communications that are necessary to:
- confirm a transaction;
- deliver a report;
- respond to support requests;
- provide important service notices; or
- communicate material changes affecting the service.
Marketing communications will be sent only where permitted by applicable law, and you may unsubscribe from marketing communications at any time.
Comply With Legal Obligations
We may process information where reasonably necessary to:
- comply with applicable law;
- meet accounting or tax requirements;
- respond to legally valid requests;
- establish or defend legal claims; or
- enforce our agreements.
5. Legal Bases for Processing
Where applicable law requires us to identify a legal basis, we may rely on one or more of the following, depending on the circumstances:
Contractual necessity
Where processing is necessary to provide a service or digital report you requested.
Consent
Where you have affirmatively agreed to particular processing.
Explicit or separate consent
Where required for sensitive or health-related personal information.
Legitimate interests
Where permitted by law and where our legitimate interests are not overridden by your rights and interests, such as maintaining security, preventing fraud, and improving basic service reliability.
Legal obligations
Where processing is required to comply with applicable law.
We do not rely on legitimate interests as a substitute for consent where applicable law specifically requires consent for processing health or other sensitive information.
6. Health and Sensitive Personal Information
Assessment responses and constitution-related information may qualify as sensitive personal information, health data, special-category data, or consumer health data under applicable law.
We apply additional rules to this information.
In particular, QINGHE is designed so that health-related information is used primarily to provide the assessment and report requested by the user.
We do not intend to use individual assessment responses or constitution results for unrelated advertising profiling.
Please read our Consumer Health Data Privacy Policy for the detailed rules governing this information.
7. Advertising and Analytics
QINGHE may use analytics or advertising services to measure general website usage or campaign performance.
Our intended data-separation rule is:
individual assessment answers, constitution scores, constitution results, and personalized report content must not be transmitted to advertising networks for targeted or cross-context behavioral advertising.
Advertising events may instead use general events such as:
- assessment started;
- assessment completed;
- checkout started; and
- purchase completed,
without including the user's health responses or constitution result.
If applicable law provides an opt-out right for advertising-related sharing, QINGHE will provide an appropriate privacy-control mechanism.
8. How We Disclose Personal Information
We may disclose personal information to service providers that perform functions on our behalf, such as:
- cloud infrastructure and hosting;
- database and storage services;
- email delivery;
- payment processing;
- customer support;
- security and fraud prevention;
- technical monitoring;
- analytics; and
- professional advisers.
Such providers should receive only the information reasonably necessary for their function and are expected to handle that information under appropriate contractual, confidentiality, and security obligations.
We may also disclose information where reasonably necessary:
- to comply with applicable law or valid legal process;
- to protect rights, safety, and security;
- to investigate fraud or abuse;
- in connection with a merger, acquisition, financing, restructuring, or sale of assets, subject to applicable legal requirements; or
- with your direction or consent.
9. Sale and Sharing of Personal Information
QINGHE does not sell individual consumer health data.
QINGHE does not sell individual assessment answers or constitution results.
QINGHE does not provide individual assessment answers or constitution results to data brokers.
QINGHE is designed not to share individual consumer health data for cross-context behavioral advertising or targeted advertising.
For other non-health personal information, certain advertising or analytics technologies may constitute “sharing,” “targeted advertising,” or similar activity under some privacy laws even where money is not exchanged.
Where those laws apply, we will provide the legally required choice mechanisms.
10. Payment Processing
Payments may be processed by one or more independent payment service providers.
Those providers may process information necessary to complete your transaction, prevent fraud, comply with financial regulation, and provide payment services.
Their processing may be governed by their own privacy notices.
QINGHE should not send your individual questionnaire responses, constitution result, or personalized report content to a payment provider unless strictly necessary and clearly disclosed.
11. International Data Transfers
QINGHE may operate internationally and may use service providers located in countries or regions different from your own.
Where personal information is transferred across borders, we will take measures required by applicable law.
For individuals in the European Economic Area, United Kingdom, or other jurisdictions requiring transfer safeguards, this may include recognized contractual safeguards or other lawful transfer mechanisms where applicable.
For personal information subject to the laws of the People's Republic of China, cross-border transfers will be handled in accordance with applicable data-transfer requirements, including notice, consent, and other required transfer mechanisms where applicable.
The specific hosting locations and international recipients used by QINGHE will be reflected in this Policy or other required notices where disclosure is legally required.
12. Data Retention
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, unless a longer period is required or permitted by law.
Retention periods may differ depending on the information involved.
For the production version of QINGHE, our intended minimization approach is:
- Assessment responses: retained only for the period reasonably necessary to calculate, generate, deliver, troubleshoot, or restore the requested report, and then deleted or deidentified according to our operational retention schedule.
- Generated results and reports: retained only where necessary to provide report access, support the user, or meet legitimate operational requirements.
- Purchase and accounting records: retained for the period required by applicable tax, accounting, fraud-prevention, or financial laws.
- Support records: retained for a reasonable period necessary to resolve disputes, document service history, and improve support.
- Security logs: retained for a limited period reasonably necessary for security, abuse prevention, and technical diagnostics.
We may retain deidentified or aggregated information where it can no longer reasonably be linked to an identifiable individual.
13. Your Privacy Rights
Depending on where you live and the law that applies to QINGHE, you may have rights to:
- request access to personal information;
- obtain information about how it is processed;
- correct inaccurate personal information;
- request deletion;
- request restriction of certain processing;
- object to certain processing;
- withdraw consent;
- obtain a portable copy of certain information;
- opt out of certain sales, sharing, or targeted advertising;
- limit certain uses of sensitive personal information; and
- lodge a complaint with an applicable data-protection authority.
These rights are not absolute and may be subject to legal exceptions.
To submit a privacy request, contact:
payments@qinghewell.com
We may take reasonable steps to verify your identity before acting on a request.
You will not be unlawfully discriminated against for exercising applicable privacy rights.
14. European Economic Area and United Kingdom
Where the GDPR, UK GDPR, or similar law applies, you may have rights including access, correction, deletion, restriction, objection, portability, and withdrawal of consent.
Where we rely on consent, withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
Health-related personal information will be processed only where an appropriate legal basis for the underlying processing and an applicable condition for processing special-category data exist.
You may also have the right to complain to the data-protection supervisory authority responsible for your jurisdiction.
15. United States Privacy Rights
Residents of certain U.S. states may have additional rights under state privacy laws.
Depending on the law and whether QINGHE falls within its scope, these may include rights to:
- know or access personal information;
- delete personal information;
- correct inaccuracies;
- obtain data portability;
- opt out of sale;
- opt out of targeted or cross-context behavioral advertising;
- limit certain uses of sensitive personal information; and
- appeal certain privacy-request decisions.
California law, where applicable, may provide additional rights concerning sensitive personal information and the sale or sharing of personal information.
Consumer health data is addressed separately in our Consumer Health Data Privacy Policy.
16. Users in the People's Republic of China
Where the Personal Information Protection Law of the People's Republic of China and related rules apply, users may have rights concerning:
- notice and explanation of processing;
- restriction or refusal of certain processing;
- access and copying;
- correction;
- deletion;
- withdrawal of consent; and
- other rights provided by applicable law.
Sensitive personal information will be processed only where there is a specific purpose, sufficient necessity, and appropriate protective measures.
Where separate consent is legally required, QINGHE will request it separately.
Where personal information is transferred outside mainland China, additional notice, consent, contractual, assessment, certification, or other legally required safeguards will be implemented where applicable.
17. Automated Assessment Processing
QINGHE uses predefined scoring or computational logic to interpret questionnaire responses and generate constitution results.
This processing is intended to provide the assessment and report requested by the user.
The result is not intended to make decisions producing legal effects or similarly significant effects concerning employment, credit, insurance, eligibility, healthcare access, or other comparable matters.
QINGHE's assessment is a wellness and educational tool and is not a medical diagnostic system.
18. Data Security
We use administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, loss, or misuse.
Access to sensitive and health-related information should be limited to personnel and service providers who reasonably need such access.
No internet-based service can guarantee absolute security, and we cannot guarantee that unauthorized access or security incidents will never occur.
Where legally required, we will provide notices concerning qualifying personal-data or health-data breaches.
19. Children
QINGHE is intended for adults aged 18 years or older.
We do not intentionally offer the assessment to children.
If we become aware that we have collected personal information from a child in circumstances requiring parental consent or where collection is otherwise prohibited, we will take appropriate steps to delete or otherwise address the information.
20. Changes to This Policy
We may update this Privacy Policy when our services, technologies, data practices, or legal obligations change.
When changes are material, we will provide notice where required by law.
The “Last Updated” date at the top of this Policy indicates when the current version was issued.
Where applicable law requires new consent before a new use of sensitive or health information, updating this Policy alone will not replace that consent.
21. Contact Us
For privacy questions, requests, or complaints, contact:
KANG FU LIN LIMITED
payments@qinghewell.com
If you are exercising a statutory privacy right, please include enough information for us to identify the relevant record and securely verify the request without providing unnecessary sensitive information.