Privacy Policy

Privacy Policy

Last updated: April 6, 2026

Cihang (cihang.app) is committed to protecting your personal data. This Privacy Policy explains what data we collect, why we collect it, how we use it, and the rights you have under applicable law — including the EU General Data Protection Regulation (GDPR), UK GDPR, Singapore's Personal Data Protection Act 2012 (PDPA), and Malaysia's Personal Data Protection Act 2010 (PDPA).

1. Data Controller

For data-related inquiries, contact our Data Protection Officer at privacy@cihang.app.

2. Service Jurisdiction

Cihang is intended for users in Singapore, Malaysia, and the global Chinese-speaking diaspora. Cihang does not target or serve users in mainland China (PRC). This service has not obtained the Internet Religious Information Services Permit (互联网宗教信息服务许可) required under PRC law for religious content services. Users in the PRC access this service at their own discretion.

3. Personal Data We Collect

We collect only the data necessary to provide the service (data minimisation):

  • Account identifiers (e.g. email address or third-party auth token) when you create an account.
  • Fortune drawing history, stored locally on your device and, if signed in, synced in encrypted form to your account.
  • Anonymised usage analytics (page views, feature interactions) to improve the service. No personal identifiers are attached.
  • Standard server logs (IP address, user agent) retained for up to 90 days for security and abuse prevention.

4. Religious & Sensitive Data

By using Cihang's devotional features — including fortune drawing, sutra reading, shrine offerings, and the Dharma Mirror — you may reveal information about your religious beliefs. Under GDPR Article 9, Malaysia's PDPA Section 40, and similar laws, this constitutes sensitive or special-category data. We process this data only with your explicit consent, which you provide during account creation. You may withdraw this consent at any time by contacting privacy@cihang.app, though withdrawal may affect your ability to use certain devotional features.

5. Purposes & Legal Bases

We process your data for the following purposes and on the following legal bases (GDPR Article 6):

  • Providing and maintaining the service — lawful basis: performance of a contract (GDPR Art. 6(1)(b)).
  • Security monitoring and fraud prevention — lawful basis: legitimate interests (GDPR Art. 6(1)(f)).
  • Service improvement through anonymised analytics — lawful basis: legitimate interests (GDPR Art. 6(1)(f)).
  • Compliance with applicable law — lawful basis: legal obligation (GDPR Art. 6(1)(c)).

6. Data Retention

Account data is retained while your account is active and deleted within 30 days of account deletion.

Server logs are retained for up to 90 days.

Anonymised analytics data may be retained for up to 24 months.

Dharma Mirror and Ciyun Chat interaction logs are retained for rate-limiting purposes for 90 days, then permanently deleted.

Fortune drawing records (lot number, timestamp, encrypted question) are retained while your account is active and deleted within 30 days of account deletion.

Shrine offering records (type and timestamp) are retained while your account is active and deleted within 30 days of account deletion.

Encrypted database backups are retained for up to 30 days and then automatically purged.

7. International Data Transfers

Your data is processed on servers in Singapore (AWS ap-southeast-1). Certain services involve transfers to the United States: Stripe Inc. (payment processing, participant in the EU-US Data Privacy Framework), OpenRouter and upstream AI model providers (AI-generated dharma reflections — prompts are processed transiently and not stored by the provider), and Google LLC (OAuth authentication, participant in the EU-US Data Privacy Framework). Where personal data is transferred from the EEA/UK to the US, we rely on the EU-US Data Privacy Framework and Standard Contractual Clauses (SCCs). For transfers involving Singapore or Malaysia resident data, we apply safeguards consistent with the respective PDPA frameworks.

8. Your Rights

Depending on your jurisdiction, you have the following rights regarding your personal data:

GDPR & UK GDPR (EU / EEA / UK residents)

  • Right of access — obtain a copy of your personal data.
  • Right to rectification — correct inaccurate or incomplete data.
  • Right to erasure — request deletion of your data ('right to be forgotten').
  • Right to data portability — receive your data in a structured, machine-readable format.
  • Right to object — object to processing based on legitimate interests.
  • Right to restriction — limit how we process your data in certain circumstances.
  • Right to lodge a complaint with your national supervisory authority (e.g. your country's data protection authority).

Singapore Personal Data Protection Act (PDPA)

  • Right of access — request access to your personal data held by us.
  • Right to correction — request correction of errors in your personal data.
  • Right to withdraw consent — withdraw consent for the collection, use, or disclosure of your data at any time.
  • Right to data portability — request a copy of your data in a commonly used format.

Malaysia Personal Data Protection Act 2010 (PDPA)

  • Right of access — request access to your personal data.
  • Right to correction — request correction of inaccurate personal data.
  • Right to withdraw consent — withdraw consent for the processing of your personal data at any time.

To exercise any of these rights, contact our Data Protection Officer at privacy@cihang.app. We will respond within 30 days (or within the timeframe required by applicable law).

9. Children's Privacy

Cihang is not directed at children under 16. We do not knowingly collect personal data from children under 16. If you believe we have inadvertently collected data from a child under 16, please contact us immediately so we can delete it. If you are between 16 and 18, use of Cihang requires the consent of a parent or legal guardian.

10. Security & Privacy by Design

We apply privacy-by-design principles throughout the service. Fortune questions are encrypted client-side using AES-256-GCM with a unique key generated in your browser before reaching our servers. We never store plaintext copies. We regularly review our data practices and security controls.

11. Third-Party Services

We use a limited number of third-party services (e.g. authentication provider, cloud infrastructure). Each is bound by a data processing agreement and is only permitted to process your data as directed by us for the specified purpose.

12. Changes to This Policy

We may update this policy from time to time. Material changes will be notified via in-app notices. The 'Last updated' date at the top reflects the most recent revision. Continued use after a change constitutes acceptance.

13. Contact

For privacy requests, data subject rights exercises, or questions about this policy, contact our Data Protection Officer at privacy@cihang.app.