1. Introduction
Welcome to ShanHai Guardians (“we,” “our,” or “us”). We are committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, store, and safeguard your information when you visit our website https://www.benmingshou.com (the “Site”) or use our virtual spiritual animal reading service (the “Service”).
Please read this policy carefully. By accessing the Site or using the Service, you acknowledge that you have understood and agreed to the practices described herein.
2. Data Controller Identity
The data controller responsible for your personal data is:
ShanHai Guardians
Email: shanhai@benmingshou.com
Server Location: Singapore
For the purposes of the EU General Data Protection Regulation (GDPR) and the UK Data Protection Act, we act as the data controller. For California residents, we comply with the California Consumer Privacy Act (CCPA), as amended.
3. Data Protection Officer & EU Representative
Data Protection Officer (DPO):
We have designated a Data Protection Officer to oversee compliance with this policy. You may contact the DPO at:
Email: shanhai@benmingshou.com
EU Representative:
In compliance with Article 27 of the GDPR, we have appointed an EU-based representative. You may contact them for matters related to the processing of your personal data within the European Union:
Email: shanhai@benmingshou.com
4. What Data We Collect
We collect and process the following categories of personal data:
| Category | Examples Collected | Purpose of Collection |
| Identity Data | Name, birth date (for readings) | To generate personalized spiritual animal readings |
| Contact Data | Email address | To deliver your reading report, send service updates |
| Transaction Data | Payment ID, purchase amount, timestamp | To process payments and maintain records |
| Technical Data | IP address, browser type, time zone, operating system | For website functionality, security, and analytics |
| Usage Data | Pages visited, time spent, click patterns | To improve our Site and Service |
| Communication Data | Customer service inquiries, feedback | To respond to your requests |
We do not collect sensitive categories of data (e.g., race, health, biometric data) unless voluntarily provided. Birth date information, when used for readings, is processed strictly for service delivery and not for identification or profiling.
5. How We Collect Your Data
We collect data through:
- Direct Interactions: When you fill out forms, make a purchase, subscribe to our newsletter, or contact us.
- Automated Technologies: As you interact with our Site, we automatically collect Technical and Usage Data via cookies, server logs, and similar technologies.
- Third-Party Service Providers: We may receive limited Technical Data from analytics providers (e.g., Google Analytics) and payment processors (e.g., Stripe, PayPal).
6. Legal Bases for Processing (GDPR Residents)
If you are located in the European Economic Area (EEA) or the UK, we rely on the following legal bases:
| Purpose of Processing | Legal Basis |
| To deliver your purchased spiritual animal reading | Performance of a contract |
| To process payments and prevent fraud | Legitimate interests (to operate our business securely) |
| To send you service-related emails (e.g., delivery, updates) | Legitimate interests (to provide customer support) |
| To send marketing communications | Your consent (which you may withdraw at any time) |
| To analyze Site usage and improve our Service | Legitimate interests (to enhance user experience) |
| To comply with legal obligations (e.g., tax records) | Legal obligation |
Where we rely on legitimate interests, we have assessed that such processing does not override your fundamental rights and freedoms.
7. Your Data Protection Rights
Depending on your jurisdiction, you may have the following rights:
| Right | Description |
| Right to be informed | You have the right to know what data we collect and how we use it. |
| Right of access | You may request a copy of your personal data. |
| Right of rectification | You may ask us to correct inaccurate or incomplete data. |
| Right to erasure | You may request that we delete your personal data, subject to legal obligations. |
| Right to restrict processing | You may ask us to limit how we process your data in certain circumstances. |
| Right to data portability | You may request your data in a structured, machine-readable format. |
| Right to object | You may object to processing based on legitimate interests or direct marketing. |
| Right to withdraw consent | Where processing is based on consent, you may withdraw it at any time. |
| Right regarding automated decisions | You have the right not to be subject to decisions based solely on automated processing. |
For California Residents (CCPA/CPRA): You additionally have the right to know the categories of personal information we have collected, sold, or disclosed; the right to opt out of the sale or sharing of personal information (note: we do not sell personal data); and the right to non-discrimination for exercising your rights.
To exercise any of these rights, contact us at Email: shanhai@benmingshou.com. We will respond within the legally required timeframe, typically 30 days.
8. Cookies and Tracking Technologies
We use cookies and similar technologies on our Site. Cookies are small text files stored on your device that help us improve functionality and analyze traffic.
Types of Cookies We Use:
| Cookie Type | Purpose | Examples |
| Strictly Necessary | Essential for Site operation and security. | Session ID, shopping cart |
| Analytics / Performance | Understand how visitors use our Site. | Google Analytics |
| Functional | Remember your preferences. | Language settings |
Your Consent:
When you first visit our Site, a cookie banner will ask for your consent to deploy non-essential cookies. You may withdraw consent or adjust settings at any time via the [Cookie Settings] link in the Site footer. You can also configure your browser to refuse cookies, but this may affect Site functionality.
We do not use cookies marketed for targeted advertising on this Site at this time.
9. International Data Transfers
Our servers are located in Singapore. Your data will be processed and stored there. Singapore is recognized as a jurisdiction with adequate data protection standards by various international bodies.
For EEA and UK Residents:
When we transfer your personal data from the EEA or UK to Singapore, we ensure appropriate safeguards are in place, as required by Article 46 of the GDPR. These safeguards include:
- Standard Contractual Clauses (SCCs): We use the European Commission as approved standard contractual clauses for data transfers.
- A rigorous assessment of the laws and practices of the destination country to ensure your data rights remain protected.
- You may request a copy of these safeguards by contacting our DPO.
10. Data Sharing and Disclosure
We do not sell your personal data. We may share your data only in the following circumstances:
- Service Providers: Trusted third-party companies that assist us in operating our Site and Service (e.g., hosting provider, email delivery service, payment processor). These providers are contractually bound to process your data solely on our instructions and in compliance with this policy.
- Legal Compliance: If required by law, we may disclose data to comply with a valid legal process, court order, or government request.
- Business Transfer: In the event of a merger or acquisition, your data may be transferred to the new entity, with prior notice provided.
11. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy, or as required by law.
| Data Category | Retention Period |
| Transaction Records | Retained for tax and accounting purposes (typically 7-10 years). |
| Reading Request Data | Retained as long as your account is active. Upon request, we will delete or anonymize your reading history. |
| Marketing Consent Records | Retained indefinitely to demonstrate compliance, or until consent is withdrawn. |
| Technical / Analytics Data | Retained in anonymized form. Raw IP logs are deleted or anonymized within 30 days. |
12. Children’s Privacy
Our Service is not directed to individuals under the age of 16 (or the applicable age of digital consent in your country). We do not knowingly collect personal data from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately. We will promptly delete any such data from our records.
13. Refund Policy and Consumer Rights
For EU/EEA Residents:
Under EU consumer protection laws, you generally have a 14-day right of withdrawal for digital services purchased online. However, you will be asked to expressly acknowledge and agree that your purchased spiritual animal reading constitutes the immediate delivery of digital content, and that you thereby lose your right of withdrawal once delivery has commenced.
A confirmation checkbox stating this will be provided at checkout. For any technical issues with receiving your reading, please contact us, and we will ensure delivery.
14. Data Security
We implement appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures include:
- Encryption of data in transit (TLS/SSL)
- Access controls and authentication
- Regular security assessments
- Staff awareness training on data protection
No online service is 100% secure. In the unlikely event of a data breach that poses a high risk to your rights, we will notify you and the relevant supervisory authority without undue delay, as required by law.
15. Changes to This Privacy Policy
We may update this policy from time to time. The “Last Updated” date at the top will reflect any changes. We will notify you of material changes by posting a prominent notice on our Site or, where appropriate, by email. Continued use of the Service after changes constitutes acceptance of the revised policy.
16. Contact Us
If you have questions, concerns, or wish to exercise your data rights, please contact us:
Data Protection Officer
ShanHai Guardians
Email: shanhai@benmingshou.com
Supervisory Authority:
If you are located in the EEA, you have the right to lodge a complaint with your local data protection supervisory authority. We would, however, appreciate the opportunity to address your concerns first, so please contact us initially.
© ShanHai Guardians. All rights reserved.
