BJJplan PIPL Privacy Policy Addendum

Last Updated: May 4, 2025

This PIPL Privacy Policy Addendum (“Addendum”) supplements the BJJplan Privacy Policy and applies to users in the People’s Republic of China (“China”) to ensure compliance with the Personal Information Protection Law (“PIPL”). Mint Devs LLC, a limited liability company organized under the laws of Wyoming, United States (“we,” “us,” or “our”), provides this Addendum to explain how we handle personal information of Chinese users in accordance with PIPL requirements. By using the BJJplan mobile application and its cloud-based features (collectively, the “Service”), you (or your parent, if under 14) consent to the practices described in this Addendum and the Privacy Policy.

1. Scope

This Addendum applies to personal information processed by Mint Devs LLC for Chinese users, including:

Email addresses, training logs, and related data collected via the Service.
Payment information for subscriptions or one-time purchases (not collected from children under 14).
Device information, usage data, and IP addresses, as described in the Privacy Policy.

2. Legal Basis for Processing

We process personal information based on:

Consent: Your explicit consent (or parental consent for children under 14) provided during account creation or use of the Service.
Contractual Necessity: To provide the Service, such as syncing training logs or processing payments.
Legal Obligations: To comply with PIPL and other applicable laws.

3. Data Storage and Cross-Border Transfers

Storage: Personal information is stored on secure servers in Singapore operated by Mint Devs LLC or trusted third-party cloud providers. Local data is stored on your device unless synced to the cloud.
Cross-Border Transfers: By using the Service, you (or your parent, if under 14) consent to the transfer of your personal information to Singapore for processing. We implement safeguards, such as Standard Contractual Clauses, to ensure compliance with PIPL Article 38.
Purpose: Transfers are necessary to provide cloud-based features (e.g., data sync) and improve the Service.

4. Children’s Personal Information

For users under 14, we collect personal information (e.g., email, training logs) only with verifiable parental consent, as required by PIPL Article 31.
Consent methods include email confirmation, payment verification, or signed consent forms, available during account creation or at https://bjjplan.com/legal/parental-consent-zh.
Parents may contact us at [email protected] to review, modify, revoke consent, or request deletion of their child’s data.

5. Your Rights Under PIPL

As a Chinese user, you (or your parent, if under 14) have the following rights under PIPL:

Access: Request a copy of your personal information.
Correction: Request correction of inaccurate or incomplete data.
Deletion: Request deletion of your personal information, subject to legal retention requirements.
Restriction: Request restriction of processing in certain cases.
Objection: Object to processing for specific purposes.
Portability: Request transfer of your data to another provider, where feasible.
Withdraw Consent: Withdraw consent at any time, without affecting prior processing.

To exercise these rights, contact us at [email protected]. We will respond within 30 days, as required by PIPL.

6. Data Security

We implement reasonable security measures (e.g., encryption, access controls) to protect your personal information, with enhanced protections for children’s data. However, no system is completely secure, and you assume the risk of any security breaches.

We may share your personal information with third-party providers (e.g., cloud hosting, payment processors) to operate the Service, subject to strict confidentiality agreements. For children under 14, sharing is limited to providers necessary for core functionality. We do not sell or share your data for advertising purposes.

8. Data Retention

We retain your personal information only as long as necessary to provide the Service or comply with legal obligations (e.g., tax records for payments). For children under 14, data is deleted upon parental request or account termination, unless required by law. Anonymized data may be retained for analytics.

9. Contact Information

Global Contact: For PIPL-related inquiries, including exercising your rights or managing children’s data, contact:
- Mint Devs LLC
- Email: [email protected]
- Website: https://bjjplan.com
China Contact: Mint Devs LLC has not established a dedicated office or representative in China. For personal information protection inquiries, please contact us at [email protected]. We will establish a dedicated office or appoint a representative in China if required by applicable laws or as our operations expand to meet regulatory thresholds.

10. Changes to This Addendum

We may update this Addendum at any time by posting an updated version at https://bjjplan.com/legal/pipl-en. We will notify you (or parents, for children under 14) of material changes via the app or email. Continued use of the Service after such changes constitutes your (or your parent’s) acceptance of the updated Addendum.