Auto Lead Warmer Privacy Policy

Auto Lead Warmer Privacy Policy

Version: v2.0 | Effective Date: 2025-10-12 | Applicable Scope: Google Sheets Add-on

Updated for Google CASA Verification Compliance

Thank you for using Auto Lead Warmer (the “Add-on”), developed under the brand hireFrankie. We respect your privacy and data security. This Privacy Policy explains how we collect, use, share, retain, and protect your information when you use the Add-on, as well as your rights regarding your personal data.

1. Product and Data Roles

Product Name: Auto Lead Warmer (Google Sheets Add-on)

Purpose: Automating post-event lead warming in Google Sheets (lead profiling, personalized email drafting, and scheduling).

Data Controller: The Google account owner/organization who installs and uses the Add-on.

Data Processor: The Add-on (hireFrankie) processes data only to deliver the described functionalities.

2. Data We Access

The Add-on accesses only the minimum data necessary to deliver its core functionality. Here is a comprehensive list of all data accessed:

2.1 Google Sheets Data (OAuth Scope: spreadsheets.currentonly)

What We Access:

- Cell values in the currently open spreadsheet only

- Lead information fields: Email Address, First Name, Company URL, Department, Position

- Generated content fields: Leads Profile, 1st~3rd Mail Angles, 1st~3rd Follow-up Emails

- Schedule fields: 1st~3rd Mail Schedule timestamps

- Control fields: Status, Info, Send Now checkbox

- User Info sheet data: Seminar Info, Seminar Brief, Email Signature, Email Prompts

How We Use This Permission:

- Read lead data to generate personalized content

- Write AI-generated profiles, email angles, and draft emails back to cells

- Update status, schedule, and info fields to track processing progress

- Apply formatting (row height, column width, text wrapping, frozen rows)

Important: We only access the specific spreadsheet you are actively using. We do NOT access any other spreadsheets in your Google Drive.

2.2 Gmail Send Data (OAuth Scope: gmail.send)

What We Access:

- Permission to send emails on your behalf

- Recipient email addresses (from spreadsheet)

- Email subject and body content (generated or user-edited)

How We Use This Permission:

- Send follow-up emails to leads based on schedules you set

- Send emails immediately when you check the "Send Now" box

- Record send results (success/failure status, timestamp)

Important: We only SEND emails. This scope does not allow us to read your existing Gmail messages.

2.3 Gmail Read Data (OAuth Scope: gmail.readonly)

What We Access:

- Email metadata for reply detection: subject lines, sender addresses, timestamps

- Search results for specific email threads matching subjects we sent

- Bounce notification emails from mail servers (mailer-daemon, postmaster)

- Email body content ONLY for bounce notifications to extract failure reasons

How We Use This Permission:

- Detect when leads reply to your follow-up emails (metadata only)

- Match replies by subject line and timestamp only

- Stop automated email sequences when a reply is detected

- Detect email delivery failures (bounces) by reading bounce notification emails

- Extract bounce reasons to help you identify invalid email addresses

Important:

- We do NOT read the content of emails from your leads or contacts

- We ONLY read bounce notification emails from mail servers (mailer-daemon@*, postmaster@*)

- For reply detection, we only check metadata (subject, sender, timestamp), NOT message content

2.4 External API Access (OAuth Scope: script.external_request)

What We Access:

- Permission to communicate with external APIs (Perplexity AI, OpenAI, Firebase Functions)

How We Use This Permission:

- Send minimal prompts to Perplexity API to generate lead profiles

- Send minimal prompts to OpenAI API to generate email drafts and angles

- Send pixel tracking data to Firebase Functions to detect email opens

- Receive AI-generated content back from these services

2.5 User Information (OAuth Scope: userinfo.email)

What We Access:

- Your Google account email address

How We Use This Permission:

- Identify you for Firebase user management and usage tracking

- Verify payment status for AI service access

- Attribute actions to the correct user in logs

2.6 Apps Script Services (OAuth Scope: script.scriptapp)

What We Access:

- Permission to manage time-based triggers

- Permission to create add-on menu items

How We Use This Permission:

- Create hourly triggers to check and send scheduled emails

- Provide menu options for setup, processing, and debugging

2.7 Temporary Storage (PropertiesService)

What We Store:

- Sent email tracking keys (format: sent_email_{row}_{emailType})

- Each record contains: recipient email, subject, send timestamp, row index, email type

How We Use This:

- Track which emails have been sent to enable reply detection

- Auto-delete records after 30 days or when replies are detected

Important: This data is stored in Google's PropertiesService (part of Apps Script infrastructure), NOT on external servers.

3. How We Use Your Data (Detailed Data Flow)

This section explains exactly how your data flows through our system from start to finish:

3.1 Lead Profile Generation

Step 1: You enter lead information in the spreadsheet (Email, First Name, Company URL, Position, Department)

Step 2: You click "Process Leads" in the add-on menu

Step 3: We read this data from your spreadsheet

Step 4: We send the following to Perplexity API:

- Company URL

- Position

- Department (if provided)

- Your Seminar Brief (from User Info sheet)

- System prompt for profile generation

Step 5: Perplexity returns an AI-generated lead profile

Step 6: We write the profile back to the "Leads Profile" column in your spreadsheet

Step 7: No data is stored outside your spreadsheet and Google's infrastructure

3.2 Email Angle & Draft Generation

Step 1: Using the generated lead profile from step 3.1

Step 2: We send the following to OpenAI API for each of 3 follow-up emails:

- Lead Profile

- Your custom email prompt (from User Info sheet)

- First Name

- Email number (1st, 2nd, or 3rd)

Step 3: OpenAI returns AI-generated mail angles and draft email content

Step 4: We write these back to your spreadsheet columns:

- "1st/2nd/3rd Mail Angle"

- "1st/2nd/3rd Follow-up Email"

Step 5: We calculate schedule times (based on current date + intervals)

Step 6: We write schedule times to "1st/2nd/3rd Mail Schedule" columns

Step 7: We update Status to "Running" and enable the "Send Now" checkbox

Note: We use OpenAI GPT model instead of Perplexity for email generation to optimize for creative writing quality.

3.3 Automated Email Sending

Step 1: Hourly trigger checks all rows with Status = "Running"

Step 2: For each row, we compare current time with schedule times

Step 3: If schedule time has passed and email not yet sent:

a. Read email content and recipient from spreadsheet

b. Generate HTML email with tracking pixel (see 3.4)

c. Send email via Gmail using gmail.send permission

d. Mark schedule cell with strikethrough formatting

e. Record sent email metadata to PropertiesService

f. Update Info field with send timestamp

Step 4: If all 3 emails sent, update Status to "Done"

3.4 Email Open Tracking (Pixel Tracking)

Step 1: When composing email, we embed a 1x1 transparent pixel image

Step 2: Pixel URL format: https://asia-east1-auto-lead-warmer-mvp.cloudfunctions.net/pixelTracker?id={spreadsheetId}&row={rowIndex}&type={emailType}

Step 3: Data sent to Firebase Functions:

- Spreadsheet ID (to identify which sheet)

- Row index (to identify which lead)

- Email type (mail1, mail2, or mail3)

Step 4: When recipient opens email, their email client requests the pixel

Step 5: Firebase Function receives this request and logs the open event

Step 6: Open detection is written back to your spreadsheet's Info column

Step 7: You can see which emails were opened and when

3.5 Reply Detection

Step 1: Hourly trigger runs reply detection for Running leads

Step 2: We read sent email records from PropertiesService

Step 3: For each sent email, we search Gmail using:

- Query: subject:"{original subject}" from:{lead email}

- We only search for emails sent AFTER we sent our message

Step 4: We check email metadata only:

- Subject line (to match conversation thread)

- Sender address (to verify it's from the lead)

- Timestamp (to confirm it's after our sent time)

Step 5: We do NOT read the message body or content

Step 6: If reply detected:

a. Update Status to "Done"

b. Update Info with "Reply detected on {date}"

c. Delete sent email record from PropertiesService

d. Stop further automated emails for this lead

3.6 Bounce Detection (Email Delivery Failures)

Step 1: Hourly trigger runs bounce detection for recently sent emails

Step 2: We search Gmail for bounce notification emails using:

- Query: from:mailer-daemon OR from:postmaster

- We search for emails received after we sent our messages

Step 3: We read the bounce notification email body to extract:

- Bounced recipient email address

- Bounce reason (e.g., "Address not found", "Mailbox full")

- Original message details

Step 4: We match the bounced email to the corresponding lead in spreadsheet

Step 5: If bounce detected:

a. Update Info field with "Bounced: {reason}"

b. Optionally update Status to "Done" to stop further emails

c. Mark the lead as having delivery issues

Important: This is the ONLY scenario where we read email body content. We only read bounce notification emails from mail servers (mailer-daemon, postmaster), NOT emails from your leads or other contacts.

3.7 Manual "Send Now" Feature

Step 1: You check the "Send Now" checkbox for a specific email

Step 2: onEdit trigger detects this change

Step 3: We immediately send the corresponding email (same process as 3.3)

Step 4: Mark schedule with strikethrough

Step 5: Uncheck the "Send Now" box

Step 6: If all emails sent, clear the checkbox and update Status

3.8 Usage Statistics & Diagnostics

We collect the following aggregated, anonymized data for system optimization:

- AI API usage: token counts, costs, latency

- Execution statistics: trigger run times, error rates

- These logs are sent to Google Cloud Logging (Stackdriver)

- Logs are minimized to exclude personally identifiable information where possible

Legal Basis (where GDPR applies):

- Contractual necessity (Art. 6(1)(b)) - to provide the service you requested

- Legitimate interests (Art. 6(1)(f)) - to prevent abuse, ensure security, and optimize performance

4. How We Share Your Data with Third Parties

We share data with third parties only as necessary to provide the service. Here is a complete list of all third-party data sharing:

4.1 Google Services (Data Remains in Google Infrastructure)

Third Party: Google LLC (Gmail, Google Sheets, Apps Script, Cloud Logging)

Data Shared:

- ALL spreadsheet data (remains in Google Drive)

- ALL Gmail data (remains in Gmail servers)

- Execution logs (stored in Google Cloud Logging)

Purpose:

- Google provides the infrastructure for the add-on to run

- Your spreadsheet data never leaves Google's servers

- Your Gmail data never leaves Google's servers

Data Flow: Your data → Google Apps Script → Google Sheets/Gmail → Stays in Google

Important: This is NOT third-party sharing in the traditional sense. Your data stays within Google's ecosystem.

4.2 Perplexity AI (External AI Service)

Third Party: Perplexity AI (https://www.perplexity.ai/)

Exact Data Fields Sent:

For Lead Profile Generation ONLY:

- Company URL (e.g., "https://example.com")

- Position (e.g., "Marketing Manager")

- Department (e.g., "Marketing") - if provided

- Seminar Brief (your description from User Info sheet)

- System prompt (our template text for profile generation)

Data NOT Sent to Perplexity:

- Email addresses (recipient or yours)

- Full names or first names

- Any generated email content

- Any email prompts or templates

- Any data from other spreadsheet rows

- Any Gmail data

Purpose:

- Generate personalized lead profiles based on company and position information

Note: Perplexity is used ONLY for lead profile generation. Email content is generated by OpenAI (see Section 4.3).

Data Retention by Perplexity:

- Subject to Perplexity's own privacy policy

- We recommend reviewing: https://www.perplexity.ai/privacy

4.3 OpenAI (Email Generation Service)

Third Party: OpenAI (https://openai.com/)

Exact Data Fields Sent:

For Email Angle & Draft Generation (3 separate calls per lead):

- Lead Profile (previously generated by Perplexity, max 1000 characters)

- First Name (e.g., "John")

- Email Prompt (your custom template from User Info sheet, max 1500 characters per email)

- Email number indicator (1, 2, or 3)

- System prompts (our template instructions for email generation)

Data NOT Sent to OpenAI:

- Email addresses (recipient or yours)

- Full names (only first name sent)

- Any Gmail data

- Any data from other spreadsheet rows

Purpose:

- Generate personalized email angles based on lead profiles

- Draft customized follow-up email content

- Optimize for creative and persuasive writing quality

Data Retention by OpenAI:

- OpenAI retains API inputs for 30 days for abuse monitoring

- After 30 days, your data is permanently deleted

- Data is NOT used to train OpenAI models (per API usage terms)

- Learn more: https://openai.com/policies/api-data-usage-policies

4.4 Firebase Functions (Pixel Tracking Service)

Third Party: Google Firebase (part of Google Cloud Platform)

Function URL: https://asia-east1-auto-lead-warmer-mvp.cloudfunctions.net

Exact Data Fields Sent:

When email is opened by recipient:

- Spreadsheet ID (Google Drive file identifier)

- Row index (number indicating which lead, e.g., "5")

- Email type (one of: "mail1", "mail2", "mail3")

- Timestamp of email open (automatically captured by Firebase)

Data NOT Sent:

- No email addresses

- No names

- No email content

- No personal information about leads

Purpose:

- Track when emails are opened by recipients

- Write open detection data back to your spreadsheet

- Help you understand email engagement

Data Retention:

- Firebase Functions process this data in real-time

- Open events are written directly to your spreadsheet (no separate database storage)

- Function logs may be retained per Firebase Functions logging policy

Important: This tracking pixel is embedded in emails sent to your leads. When leads' email clients request this pixel upon opening emails, Firebase detects the open and updates your spreadsheet.

4.5 No Other Third-Party Sharing

We explicitly DO NOT share your data with:

- Advertising networks

- Data brokers

- Analytics services (beyond Google Cloud Logging)

- Social media platforms

- Any other third parties not listed above

4.6 Data Sale & Advertising

We do NOT:

- Sell your data to anyone

- Use your data for advertising purposes

- Use your data for purposes unrelated to this add-on's functionality

- Share data with third parties for their own marketing

4.7 Legal Compliance

We follow:

- Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy)

- Google APIs Terms of Service

- Limited Use Requirements: We only use Google user data to provide and improve user-facing features of Auto Lead Warmer

5. How We Store and Protect Your Data

5.1 Data Storage Locations

We want to be completely transparent about where your data is stored:

Location 1: Google Sheets (Your Google Drive)

What's Stored:

- ALL lead data (Email, Name, Company URL, Position, Department)

- ALL generated content (Leads Profiles, Mail Angles, Email Drafts)

- ALL scheduling data (Mail Schedules, Status, Info fields)

- User Info sheet data (Seminar Info, Email Prompts, Signature)

Who Controls It: YOU

- You own this data

- It's stored in your Google Drive

- You can edit, delete, or export it anytime

- We do NOT duplicate this data to external servers

Location 2: Google PropertiesService (Apps Script Infrastructure)

What's Stored:

- Sent email tracking records (format: sent_email_{row}_{emailType})

- Each record contains: recipient email, subject, timestamp, row index, email type

Storage Duration: Maximum 30 days, often less

- Auto-deleted after 30 days

- Deleted immediately when reply is detected

- Deleted when Status changes to "Done"

Who Controls It: Google Apps Script

- This is part of Google's Apps Script infrastructure

- Data is tied to your spreadsheet's script project

- Deleted when you uninstall the add-on

Location 3: Google Cloud Logging (Stackdriver)

What's Stored:

- Execution logs: error messages, function names, execution times

- API usage statistics: token counts, costs, latency

- Anonymized diagnostic data

Storage Duration: Per Google Cloud Logging retention policies (typically 30 days)

Who Controls It: Google Cloud Platform

Location 4: External Services (Temporary Processing Only)

Perplexity AI:

- Receives prompts temporarily for lead profile generation

- Does not persistently store in our account

- Subject to Perplexity's data retention policies

OpenAI:

- Receives prompts temporarily for email generation

- Retains data for 30 days for abuse monitoring only

- After 30 days, data is permanently deleted

- NOT used to train AI models (per OpenAI API terms)

Firebase Functions:

- Processes pixel tracking requests in real-time

- Writes open detection back to your spreadsheet

- Function logs retained per Firebase logging policy

IMPORTANT: We do NOT store your data on:

- Our own servers (we don't have any)

- Third-party databases

- Cloud storage services (AWS, Azure, etc.)

- Any location outside Google's infrastructure (except temporary API calls)

5.2 Data Protection Measures

We implement the following security practices:

Encryption in Transit:

- All API communications use HTTPS/TLS encryption

- OAuth 2.0 for authentication and authorization

- Encrypted connections to Perplexity API and Firebase Functions

Access Control:

- Only YOU can access your spreadsheet data (via Google Drive permissions)

- Apps Script runs only in YOUR Google account context

- No shared database accessible by other users

- No administrator access to your data by hireFrankie developers

Data Minimization:

- We only access fields necessary for functionality

- We only send minimal data to external APIs (Perplexity, OpenAI)

- We don't read full email bodies from leads (metadata only for replies)

- We only read bounce notification email bodies (not lead emails)

- We auto-delete tracking records after 30 days

Execution Controls:

- Trigger deduplication prevents duplicate processing

- Error handling prevents data corruption

- Quota checks prevent excessive API usage

- Input validation prevents malformed data

Code Security:

- Apps Script code is reviewed and version-controlled

- No credential storage in code (uses OAuth)

- No hardcoded API keys in client-side code

- Scoped permissions (least privilege principle)

5.3 Data Breach Notification

In the unlikely event of a data breach:

- We will notify you via email within 72 hours of discovery

- We will describe what data was affected

- We will provide steps to protect yourself

- We will report to relevant authorities as required by law (e.g., GDPR)

Important: Since your data primarily resides in Google's infrastructure, Google's security measures also protect your data. Review Google's security practices at: https://safety.google/

6. Data Retention and How to Delete Your Data

6.1 What Data We Retain and For How Long

Data Type: Spreadsheet Data (Sheets)

Retention Period: Indefinitely (until you delete it)

Reason: This is YOUR data in YOUR Google Drive

Auto-Deletion: No

Data Type: Sent Email Tracking (PropertiesService)

Retention Period: Maximum 30 days

Reason: Enable reply detection

Auto-Deletion: Yes (after 30 days OR when reply detected OR when status = Done)

Data Type: Execution Logs (Google Cloud Logging)

Retention Period: ~30 days (Google's default)

Reason: Debugging and diagnostics

Auto-Deletion: Yes (per Google Cloud Logging policies)

Data Type: Perplexity API Prompts

Retention Period: Unknown (subject to Perplexity's policies)

Reason: Lead profile generation

Auto-Deletion: Subject to third-party policy

Data Type: OpenAI API Prompts

Retention Period: 30 days maximum

Reason: Email content generation & abuse monitoring

Auto-Deletion: Yes (OpenAI automatically deletes after 30 days)

Data Type: Firebase Tracking Pixels

Retention Period: Real-time processing only (no persistent storage)

Reason: Email open tracking

Auto-Deletion: N/A (not stored)

6.2 How to Delete Your Data (Step-by-Step)

If you want to stop using Auto Lead Warmer and delete all associated data, follow these steps:

Step 1: Delete Your Spreadsheet Data

1. Open your Google Sheets spreadsheet

2. Delete the rows containing lead data (or delete entire spreadsheet)

3. This immediately removes all lead information from Google Drive

Step 2: Revoke OAuth Access

1. Go to https://myaccount.google.com/permissions

2. Find "Auto Lead Warmer" in the list

3. Click "Remove Access"

4. This immediately revokes all permissions (Gmail, Sheets, etc.)

Step 3: Uninstall the Add-on (Optional)

1. In Google Sheets, go to Extensions > Add-ons > Manage add-ons

2. Find "Auto Lead Warmer"

3. Click "Uninstall"

4. This removes the add-on from your Google account

Step 4: Delete PropertiesService Data (Automatic)

- Tracking records auto-delete within 30 days

- For immediate deletion, you can:

1. Go to Extensions > Apps Script

2. Run: PropertiesService.getScriptProperties().deleteAllProperties()

3. This clears all sent email tracking records

Step 5: Request Additional Data Deletion (If Needed)

If you want us to help verify complete data deletion:

1. Email: frankie@autofrancoai.com

2. Subject: "Data Deletion Request - Auto Lead Warmer"

3. Include: Your Google account email address

4. We will confirm within 7 business days

What Happens After Deletion:

- All automated emails stop immediately (no triggers)

- No more data is sent to Perplexity or OpenAI APIs

- No more tracking pixels embedded

- You lose access to the add-on functionality

- Your data cannot be recovered

Important Notes:

- Deletion is permanent and irreversible

- Data sent to third parties:

- OpenAI: Auto-deletes within 30 days

- Perplexity: Subject to their retention policies

- Google Cloud Logs auto-delete per Google's policies (typically 30 days)

- You can delete data anytime without contacting us (except for verification)

6.3 Data Portability (GDPR Right)

If you want to export your data:

1. Your spreadsheet data: Use Google Sheets > File > Download > CSV or Excel

2. Sent email records: Contact frankie@autofrancoai.com for export assistance

3. Execution logs: Available in Apps Script > Executions tab

7. International Transfers

Data may be processed in data centers outside your region:

- Google services: Global infrastructure (subject to Google's data transfer safeguards)

- Perplexity AI: May process in US data centers

- OpenAI: Processes in US data centers

- Firebase: Google Cloud Platform (region: asia-east1 Taiwan, but may route through other regions)

Safeguards Applied:

- Data minimization (only necessary fields sent)

- Encryption in transit (HTTPS/TLS)

- Contractual commitments with third-party services

- Compliance with Google API Services User Data Policy

8. Security

See Section 5.2 for detailed security measures.

Summary:

- OAuth 2.0 authentication

- HTTPS encryption for all API traffic

- No persistent external storage (except temporary API calls)

- Access restricted to your Google account only

- Regular security reviews and updates

9. Your Rights

You have the following rights regarding your data:

9.1 Right to Access

- View all your data directly in your Google Sheets spreadsheet

- Request a copy of data stored in PropertiesService by emailing frankie@autofrancoai.com

9.2 Right to Correction

- Edit data directly in your spreadsheet anytime

- Modify generated content, schedules, or lead information

- Changes take effect immediately

9.3 Right to Deletion

- Follow the step-by-step deletion process in Section 6.2

- Delete individual leads by removing spreadsheet rows

- Request complete data deletion by contacting frankie@autofrancoai.com

9.4 Right to Revoke Access

- Revoke permissions at https://myaccount.google.com/permissions

- Immediately stops all data processing

- Prevents further access to Gmail and Sheets

9.5 Right to Data Portability (GDPR)

- Export spreadsheet data: File > Download > CSV or Excel

- Request PropertiesService data export: frankie@autofrancoai.com

- Receive data in machine-readable format

9.6 Right to Object

- Stop automated processing by changing Status to "Done"

- Use "Stop New Processing" menu option

- Delete time-based triggers in Apps Script

9.7 Right to Complain

- GDPR users: File complaints with your local supervisory authority

- Contact us first at frankie@autofrancoai.com to resolve issues

- We will respond within 7 business days

10. Children’s Privacy

This Add-on is intended for business/professional use. It is not directed at children under 13. If child data is inadvertently processed, please contact us for deletion.

11. Updates

We may update this policy due to legal, functional, or operational changes. The updated version and effective date will be posted. Significant changes will be reasonably notified.

12. Contact Us

For questions, requests, or complaints:

Email: frankie@autofrancoai.com

Or via Add-on Menu Debug Tools > Contact (if enabled).

13. Summary for Google Workspace Marketplace

Quick Overview of Data Practices:

Data Accessed:

- Current spreadsheet only (not all spreadsheets in Drive)

- Gmail send permission and reply detection (metadata only)

- Your Google account email for user identification

Data Usage:

- Generate AI-powered lead profiles and email drafts

- Send automated follow-up emails on your schedule

- Detect replies to stop email sequences

Data Sharing:

- Perplexity AI: Lead profile generation (company URL, position, seminar brief)

- OpenAI: Email generation (lead profile, first name, email prompts) - 30-day retention

- Firebase Functions: Email open tracking (spreadsheet ID, row number, email type only)

- Google Services: All core data stays in Google infrastructure

Data Storage:

- Your spreadsheet data: Stays in your Google Drive (you own it)

- Temporary tracking: PropertiesService, auto-deleted after 30 days

- No external servers or databases

Data Protection:

- OAuth 2.0 authentication

- HTTPS encryption for all communications

- Access restricted to your Google account only

- No data sold or used for advertising

How to Delete Your Data:

1. Revoke access at https://myaccount.google.com/permissions

2. Delete your spreadsheet from Google Drive

3. Tracking data auto-deletes within 30 days

Compliance:

- Google API Services User Data Policy (Limited Use)

- Google APIs Terms of Service

- GDPR-compliant (data portability, deletion, access rights)

Contact:

- Email: frankie@autofrancoai.com

- We respond within 7 business days

14. Enterprise & Legal

For Enterprise DPA/SCC Templates:

If your organization requires a Data Processing Agreement (DPA) or Standard Contractual Clauses (SCC), please contact frankie@autofrancoai.com

Conflict with Local Regulations:

In case of conflict between this policy and local privacy regulations, the stricter requirements will prevail.

Governing Law:

This Privacy Policy is governed by the laws of Taiwan (Republic of China), where the developer is based.