Privacy Policy

1. Introduction

Nanjing Du Pei De Network Technology Co., Ltd., operating as Du Virtue (hereafter referred to as Du Virtue, we, us, or our), is committed to protecting the privacy and personal data of individuals who interact with our website, services, and communications. This Privacy Policy explains how we collect, use, disclose, retain, and safeguard information when you visit our website at https://www.duvirtue.buzz (the Site) or engage with our technology consulting services.

Du Virtue provides computer systems design, cloud architecture, cybersecurity advisory, artificial intelligence consulting, data integration, and digital transformation services to enterprises globally. In the course of delivering these services and operating our Site, we may process personal data. This policy describes our practices in full compliance with applicable data protection laws, including but not limited to the General Data Protection Regulation (EU GDPR), the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), and the Personal Information Protection Law of the People's Republic of China (PIPL).

By accessing our Site or using our services, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree with any part of this policy, you should discontinue use of our Site and services immediately.

2. Information We Collect

We collect categories of personal data necessary to operate our business, provide our consulting services, and communicate with prospective and current clients. The specific data we collect depends on the nature of your interaction with Du Virtue.

2.1 Information You Provide Directly

• Contact and Identity Data: When you submit a contact form on our Site, email us, or otherwise initiate communication, we collect your full name, email address, phone number (if provided), company name, job title, and the content of your message.
• Engagement Data: If you enter into a consulting engagement with Du Virtue, we may collect business contact details, project requirements, system specifications, architectural documentation, and other technical data necessary to deliver our professional services.
• Communication Records: Copies of correspondence, including emails, meeting notes, and call summaries, that you send to us or that we generate in the ordinary course of client communication.

2.2 Information Collected Automatically

• Technical Log Data: When you visit our Site, our servers automatically record information sent by your browser, including your IP address, browser type and version, operating system, referring URLs, pages visited, timestamps, and request methods.
• Usage Analytics: We collect aggregated and anonymized data about how visitors interact with our Site — which pages are viewed, dwell time, scroll depth, and interaction events. This data is collected through privacy-respecting analytics tools and does not include personally identifiable information unless you have explicitly provided it.
• Device Information: Device type, screen resolution, language preferences, and time zone settings transmitted by your browser.

2.3 Information We Do Not Collect

Du Virtue does not collect, process, or store sensitive personal data (as defined under GDPR Article 9) through our Site. We do not process payment card information directly on our Site. We do not engage in automated decision-making or profiling that produces legal or similarly significant effects on individuals.

3. Purpose and Legal Basis for Processing

We process personal data only for specified, explicit, and legitimate purposes. The following table summarizes the purposes for which we process personal data and the corresponding legal bases under the GDPR and equivalent legal frameworks.

3.1 Contractual Necessity (GDPR Article 6(1)(b))

• To respond to inquiries submitted through our contact form or via email.
• To negotiate, enter into, and perform consulting service agreements with clients.
• To deliver the professional services described in an active statement of work or engagement letter.

3.2 Legitimate Interests (GDPR Article 6(1)(f))

• To operate, maintain, and improve the performance and security of our Site.
• To analyze aggregated usage patterns to inform content and service development.
• To communicate with existing clients about service updates, relevant industry insights, or changes to our terms.
• To protect our legal rights, enforce our Terms of Service, and prevent fraud or abuse.
• To maintain internal business records for administrative and audit purposes.

3.3 Consent (GDPR Article 6(1)(a))

• Where required by applicable law, we will obtain your explicit consent before placing non-essential cookies on your device or sending marketing communications.
• You may withdraw consent at any time by contacting us at office@duvirtue.buzz. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

3.4 Legal Obligation (GDPR Article 6(1)(c))

• To comply with applicable laws, regulations, court orders, or governmental requests in the People's Republic of China, the European Union, the United States, and other jurisdictions where we operate.
• To maintain records required under tax, corporate, and commercial laws of the PRC.

4. Data Sharing and Disclosure

Du Virtue does not sell, rent, or trade personal data to third parties for their own marketing purposes. We share personal data only in the following limited circumstances:

4.1 Service Providers and Subprocessors

We engage carefully vetted third-party service providers to perform functions on our behalf, including website hosting, email delivery, analytics, and cloud infrastructure. These providers act as data processors under our instruction and are contractually bound to implement appropriate technical and organizational security measures. Current categories of subprocessors include:

• Cloud Hosting: Infrastructure providers that host our Site and internal systems.
• Email Services: Providers that facilitate business email delivery and communication.
• Analytics: Privacy-focused analytics services that process anonymized usage data.

A current list of subprocessors is available upon request by emailing office@duvirtue.buzz.

4.2 Legal and Regulatory Disclosures

We may disclose personal data where required by law, regulation, legal process, or enforceable governmental request — including to comply with the laws of the People's Republic of China, the European Union, or other applicable jurisdictions. We will notify you of such disclosure where legally permitted.

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or a portion of Du Virtue's assets, personal data may be transferred as part of that transaction. We will provide notice on our Site and, where feasible, direct communication to affected individuals before personal data becomes subject to a different privacy policy.

4.4 With Your Consent

We may share personal data with third parties for purposes not described in this policy only with your explicit prior consent.

5. Cookies and Tracking Technologies

Our Site uses cookies and similar technologies to ensure technical functionality, enhance security, and understand aggregate usage patterns. A cookie is a small text file placed on your device by a web server.

5.1 Types of Cookies We Use

• Strictly Necessary Cookies: Required for the Site to function — these enable core features such as page navigation, form submission security, and session management. The Site cannot operate properly without these cookies, and they do not require consent under applicable law.
• Performance and Analytics Cookies: These cookies collect aggregated, anonymized information about how visitors use our Site — which pages are most frequently visited, how users navigate between pages, and whether users encounter errors. We use this data exclusively to improve the Site experience and do not link it to identifiable individuals.
• Functional Cookies: These cookies remember choices you make — such as language or region preferences — to provide a more personalized experience.

5.2 Cookie Management

Most web browsers allow you to control cookie behavior through their settings. You can configure your browser to refuse all cookies, accept only first-party cookies, or delete cookies when you close your browser. Please note that disabling strictly necessary cookies may impair the functionality of the Site. For detailed guidance on managing cookies in your specific browser, consult the browser's help documentation or visit https://www.allaboutcookies.org.

5.3 Do Not Track

Our Site does not respond to browser Do Not Track (DNT) signals at this time, as no uniform industry standard for DNT has been adopted. We do, however, honor Global Privacy Control (GPC) signals as required under CCPA/CPRA.

6. Data Security

Du Virtue implements technical, administrative, and physical security measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures are proportionate to the sensitivity of the data and the risk posed by processing.

Our security practices include but are not limited to:

• Encryption of data in transit using Transport Layer Security (TLS 1.3) across all Site communications.
• Encryption of data at rest using industry-standard algorithms (AES-256).
• Strict access controls and the principle of least privilege across all internal systems.
• Multi-factor authentication for administrative access to infrastructure and data stores.
• Regular security assessments, vulnerability scanning, and penetration testing of our digital infrastructure.
• Security awareness training for all personnel with access to personal data.
• Incident response procedures that ensure prompt detection, containment, and notification in the event of a data breach, consistent with applicable legal obligations.

While we employ commercially reasonable safeguards, no method of electronic storage or transmission over the Internet is completely secure. We cannot guarantee absolute security of personal data, and you provide information to us at your own risk. In the event of a data breach that affects your personal data, we will notify you and applicable regulatory authorities as required by law.

7. Your Data Protection Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data. Du Virtue will respond to all valid requests within the timeframes required by applicable law — typically within 30 days for GDPR requests and 45 days for CCPA/CPRA requests (extendable as permitted by law).

7.1 Rights Under GDPR (EU/EEA and UK Residents)

• Right of Access (Article 15): You may request confirmation of whether we process your personal data and, if so, obtain a copy of that data along with information about how it is processed.
• Right to Rectification (Article 16): You may request correction of inaccurate or incomplete personal data we hold about you.
• Right to Erasure (Article 17): Also known as the right to be forgotten — you may request deletion of your personal data where there is no compelling reason for its continued processing.
• Right to Restriction (Article 18): You may request that we limit processing of your personal data in certain circumstances — for example, while we verify the accuracy of data you have contested.
• Right to Data Portability (Article 20): You may request your personal data in a structured, commonly used, machine-readable format and have the right to transmit that data to another controller.
• Right to Object (Article 21): You may object to processing based on legitimate interests, including profiling. You have an absolute right to object to processing for direct marketing purposes.
• Right to Withdraw Consent (Article 7(3)): Where processing is based on consent, you may withdraw that consent at any time.
• Right to Lodge a Complaint (Article 77): You have the right to lodge a complaint with a supervisory authority in your EU member state of residence, place of work, or place of the alleged infringement.

7.2 Rights Under CCPA/CPRA (California Residents)

• Right to Know: You may request disclosure of the categories and specific pieces of personal data we have collected about you in the preceding 12 months, the categories of sources, the business or commercial purpose for collection, and the categories of third parties with whom we share the data.
• Right to Delete: You may request deletion of personal data we have collected from you, subject to certain exceptions under the CCPA.
• Right to Correct: You may request correction of inaccurate personal data we maintain about you.
• Right to Opt Out of Sale and Sharing: Du Virtue does not sell personal data as defined under CCPA/CPRA and does not share personal data for cross-context behavioral advertising. No opt-out is therefore applicable.
• Right to Limit Use of Sensitive Personal Information: Du Virtue does not use or disclose sensitive personal information for purposes beyond those permitted under CPRA.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights — including by denying services, charging different prices, or providing a different quality of service.

7.3 Rights Under PIPL (PRC Residents)

• Right to Know and Decide: You have the right to know and make decisions regarding the processing of your personal data, and the right to restrict or refuse processing by others, except as otherwise provided by PRC law.
• Right to Access and Copy: You may request access to and obtain a copy of your personal data from us.
• Right to Rectification and Completion: You may request correction or completion of your personal data.
• Right to Deletion: You may request deletion of your personal data where the purpose of processing has been achieved, the retention period has expired, or processing is no longer necessary.
• Right to Portability: You may request to transfer your personal data to another personal information processor designated by you, where conditions prescribed by the Cyberspace Administration of China are met.

7.4 Exercising Your Rights

To exercise any of the rights described above, please contact us at office@duvirtue.buzz. We may need to verify your identity before processing your request, which may involve requesting additional information to confirm that you are the individual to whom the data relates. We will respond to your request within the statutory timeframe applicable to your jurisdiction.

8. Children's Privacy

Du Virtue's Site and services are not directed to individuals under the age of 16, and we do not knowingly collect personal data from children. If you are a parent or guardian and believe that your child has provided us with personal data without your consent, please contact us immediately at office@duvirtue.buzz. Upon verification, we will take prompt steps to delete such data from our systems. If we become aware that we have inadvertently collected personal data from a child under 16 without verified parental consent, we will delete it without undue delay.

9. International Data Transfers

Du Virtue is headquartered in Nanjing, People's Republic of China. Personal data we collect may be processed and stored in China, the United States, the European Union, or other jurisdictions where our service providers maintain facilities. These jurisdictions may have data protection laws that differ from — and may be less protective than — the laws of your country of residence.

When we transfer personal data across borders, we implement appropriate safeguards in accordance with applicable data protection laws, including:

• For transfers from the EU/EEA: reliance on European Commission adequacy decisions, or — where no adequacy decision exists — Standard Contractual Clauses (SCCs) approved by the European Commission, supplemented with additional technical and organizational measures as required.
• For transfers from the PRC: compliance with cross-border data transfer requirements under the PIPL, including security assessments, standard contracts, or certification as applicable.
• For transfers from California: contractual commitments requiring recipients to provide at least the same level of privacy protection as required under CCPA/CPRA.

You may request a copy of the specific safeguards we apply to international transfers by contacting us at office@duvirtue.buzz.

10. Third-Party Links and Services

Our Site may contain links to third-party websites, platforms, or services that are not owned or controlled by Du Virtue. This Privacy Policy applies exclusively to information collected by Du Virtue through our Site and services. We are not responsible for the privacy practices, content, or security of any third-party websites. We encourage you to read the privacy policies of every website you visit before providing personal data.

Third-party services integrated into our Site — such as font delivery services and analytics platforms — may collect data subject to their own privacy policies. Where feasible, we select providers whose privacy practices align with the standards described in this policy.

11. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required to comply with legal, regulatory, accounting, or reporting obligations. Retention periods are determined by reference to the following criteria:

• Contact form submissions and correspondence: Retained for the duration of the business relationship plus 3 years after last contact, unless a longer period is required by applicable law.
• Client engagement data: Retained for the duration of the engagement plus 7 years to comply with PRC tax and commercial record-keeping requirements.
• Website analytics data: Aggregated, anonymized analytics data may be retained indefinitely for trend analysis; identifiable log data is purged within 26 months.
• Security logs: Retained for 12 months unless required longer for ongoing security investigations.

When personal data is no longer required, we securely delete or irreversibly anonymize it in accordance with our data disposal procedures.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or regulatory requirements. When we make material changes, we will post the updated policy on this page, update the Last Updated date at the top of the policy, and — where required by law — provide additional notice, such as via email or a prominent notice on our Site.

We encourage you to review this Privacy Policy periodically. Your continued use of our Site or services after the effective date of any revised policy constitutes your acknowledgment and acceptance of those changes, subject to any consent requirements under applicable law.

13. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us using the details below. We welcome inquiries from individuals, data protection authorities, and legal representatives.

For EU-specific inquiries, you may contact our EU Representative. To request the current contact details of our EU Representative, please email office@duvirtue.buzz with the subject line: EU Representative Request.