Draft v0.1 · not legal advice

GDPR Notice

Legal basis, data minimisation, EU rights and cross-border transfers for the international edition.

Draft — not legal advice. This is a design description, not an Art. 13/14 notice. Controller identity, EU representative, DPO, retention periods and contact details are undecided, and no live service processes EU personal data yet. Counsel must review before launch.

1. Status of this notice

This page records how the international edition is designed to meet GDPR so that the engineering choices are auditable. It is not a substitute for a reviewed privacy notice or a data-processing agreement.

2. GDPR does not apply to this edition

This edition serves users in mainland China and is governed by PIPL and other applicable domestic rules, not the GDPR. The international edition's GDPR notice is provided for reference only.

Domestic-edition data stays in mainland China, uses the domestic Qianfan upstream and never traverses the Cloudflare edge. See the Privacy Policy and Cross-border pages.

3. PIPL essentials

The Personal Information Protection Law sets the rules for this edition. The principles below shape the gateway's design:

Principle	What it means here
Notice & consent	Tell users what is collected and why; obtain consent where required.
Minimum necessary	Collect only what authentication, rate limiting and billing require.
Purpose limitation	No secondary use of billing metadata for unrelated purposes.
Separate consent	Required for sensitive data, cross-border transfer, and public disclosure.
Domestic storage	Data of this edition stays in mainland China (S2 closed path).
Accountability	PIPIA and security measures proportionate to the risk.

Open item. gateway/config.py currently sets cn.log_prompt=true. Whether prompt logging is necessary and proportionate here must be assessed, disclosed to users, and reflected in a consent mechanism before launch.

4. Your rights under PIPL

Know and decide — be informed about, and restrict or refuse, the processing of your personal information.
Access and copy — obtain a copy of your personal information and, where applicable, port it.
Correct and delete — request correction or deletion under the statutory conditions.
Explain the rules — ask for an explanation of the processing rules.
Withdraw consent — withdraw consent given on that basis; where consent is not the basis, object on lawful grounds.

Request channel: to be designated. No account system or self-service data-request path exists yet.

5. Outbound transfers

This edition keeps data inside mainland China, so routine outbound transfer does not occur. If a transfer ever becomes necessary, PIPL provides three routes — CAC security assessment, the standard contract with provincial filing plus PIPIA, or certification — with a limited exemption below 100,000 non-sensitive individuals that still requires separate consent and PIPIA.

See the Cross-border notice for the full S1 / S2 / S3 model.