Privacy Policy

Liu Guo ("we", "us", "our") respects your privacy. This policy explains what personal information we collect when you use chinaadminboundaries.com, why we collect it, how long we keep it, who we share it with, and the rights you have over it. Please read it before using the Service; by using the Service you acknowledge that you have done so.

In short: we do not run accounts, we do not store your card details, we do not sell your personal information, and we do not track you across other websites.

1. Data controller

The controller responsible for your personal data is:

• Legal name — Liu Guo, an individual operating as a sole trader under the laws of China
• Jurisdiction — China
• Privacy contact — hello@chinaadminboundaries.com
• Data protection officer — not appointed. We do not carry out large-scale or sensitive processing as defined by the GDPR.

2. Information we collect

2.1 Information you give us

• Order information. The email address you enter at checkout, your name if you provide it, the dataset you bought, the amount and currency, and the transaction ID. Some of this reaches us from Waffo Pancake rather than directly from you.
• Correspondence. Emails you send to our support, billing, refund, privacy or legal address, and our replies.

There is no account and no registration, so we do not collect a password, username, profile photo, phone number or postal address.

2.2 Information collected automatically

• Technical and log data. Your IP address, browser user agent, the pages and files requested, and the time of the request. These are standard web server logs generated by our hosting provider, Cloudflare.
• Download records. Which order downloaded which file, kept so that "my download did not work" can be answered and so that a leaked link can be traced.
• Aggregate traffic statistics. Cloudflare provides us with aggregate counts of requests and bandwidth. These are not used to build a profile of any individual visitor, and we run no third-party analytics script on this site.

2.3 Information we do not collect

• Payment card data. Your card number, expiry date and security code are entered on infrastructure operated by Waffo Pancake and are never transmitted to or stored on our servers.
• Your work. The datasets are downloaded to your own computer. We never receive the maps, documents or databases you build with them.
• Precise location. We do not request or infer it.

3. How we use it

• Delivering the dataset you purchased — performance of a contract.
• Processing payments, refunds and disputes — performance of a contract.
• Responding to support and privacy requests — performance of a contract, or our legitimate interests.
• Keeping order and tax records — legal obligation.
• Preventing fraud and abuse of the Service — legitimate interests.
• Establishing or defending legal claims — legitimate interests.

We do not use your personal data for automated decision-making or profiling that produces legal effects, and we do not train machine-learning models on it.

4. Cookies and tracking

• Strictly necessary — set by Cloudflare at the network edge for security and bot mitigation. These cannot be switched off.
• Functional — your browser may store a small amount of local data so that a page setting survives a reload. This stays on your device and is not sent to us.
• Analytics — none. We do not run Google Analytics or any equivalent third-party script.
• Advertising — none. We run no advertising pixels and we do not participate in behavioural advertising networks.

Our checkout is operated by Waffo Pancake, which sets its own cookies under its own privacy policy when you pay.

5. Sharing and disclosure

We do not sell your personal information, including as "sale" is defined by the California Consumer Privacy Act. We share personal data only in these circumstances:

• Waffo Pancake — Merchant of Record and payment processor. Handles checkout, payment authorisation, tax calculation and remittance, refunds and chargeback handling. An independent controller of the payment data it processes.
• Cloudflare — hosting, content delivery and object storage for the website and the dataset files. Processes technical and log data on our behalf.
• Professional advisers — accountants or legal advisers, where necessary to meet a legal or accounting obligation or to establish a legal claim.
• Legal and regulatory — where required by law, court order or a lawful request from a competent authority.
• Business transfer — if the business is sold or merged, data may transfer to the successor. We will give notice before that happens and ensure the protections in this policy continue to apply.

6. Data security

• Encryption in transit. The site is served over HTTPS (TLS) end to end.
• No card data at rest. By design, the most sensitive category never reaches us, so it cannot leak from us.
• Least privilege. Access to order records is limited to the operator of the Service, behind a token-protected admin area.
• Minimal surface. The site is static apart from the checkout and download paths; there is no user-uploaded content and no database of user profiles.

If a security incident affects your rights or freedoms, we will notify you and any relevant supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware of it.

7. Retention

• Order and transaction records — 10 years from the end of the relevant tax year, as required by Chinese tax and accounting rules. Then deleted or anonymised.
• Support and correspondence — 3 years from the last message, so that we can resolve repeat issues. Then securely deleted.
• Download records, server and security logs — no longer than 30 days, then deleted. An automated daily pass enforces this. Aggregate traffic statistics that cannot identify an individual are kept indefinitely.

Where we are required to retain data for longer (for example, because of an ongoing dispute or investigation), we keep it only for as long as that requirement lasts.

8. Your rights

Depending on where you live, you may have some or all of the following rights. To exercise any of them, email hello@chinaadminboundaries.com. We respond within 30 days.

• Access — obtain a copy of the personal data we hold about you, together with information about how we use it.
• Rectification — have inaccurate or incomplete data corrected.
• Erasure — request deletion of your data, subject to our legal record-keeping obligations.
• Restriction — ask us to pause processing while a dispute is resolved.
• Portability — receive your data in a structured, machine-readable format.
• Objection — object to processing based on our legitimate interests.
• Withdraw consent — withdraw any consent you have given, at any time.
• Non-discrimination — California residents will not be treated differently for exercising these rights.

If you are in the EEA, the UK or Switzerland, you also have the right to lodge a complaint with your national data protection authority. We would appreciate the chance to resolve the matter first.

9. Marketing and opt-out

We do not run a mailing list and we do not send marketing email. The only messages we send are transactional: order confirmations, download links, receipts, refund confirmations, and occasional notices about changes to these policies or to the Service. You cannot opt out of these, because they are part of providing what you bought. If we ever introduce marketing messages, they will be opt-in and every message will carry a working unsubscribe link.

10. International transfers

Our hosting and payment providers operate globally, so your data may be processed outside the country you live in, including in the United States and the European Union. Where personal data leaves the EEA or the UK, we rely on the European Commission's Standard Contractual Clauses in our agreements with those providers, adequacy decisions where they apply, and, where relevant, the UK International Data Transfer Addendum. You can request a copy of the relevant safeguards by emailing hello@chinaadminboundaries.com.

Because we are established in China, personal data also travels the other way. If you are in mainland China, transfers of your personal information out of China are made under the mechanisms provided by the Personal Information Protection Law, and you can ask us which one applies to your data.

11. Children's privacy

The Service is intended for adults and is not directed at children. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us with personal data, email hello@chinaadminboundaries.com and we will delete it promptly.

12. Third-party links

This site links to third-party services, principally the Waffo Pancake checkout. This policy covers only what we collect directly. We are not responsible for the privacy practices of other organisations, and we encourage you to read their policies before providing them with personal data.

13. Changes to this policy

We may update this policy. The "last updated" date at the top of this page always reflects the current version. If a change materially affects how we use your personal data, we will notify you by email or by a prominent notice on the site at least 15 days before it takes effect.

14. Contact

• Email, for any matter — hello@chinaadminboundaries.com
• Data controller — Liu Guo · China

Privacy and data-protection requests go to the same address as everything else, and reach the person who operates the Service.

Version 1.0 · Last updated 20 October 2026 · Applies to chinaadminboundaries.com