Effective: April 13, 2026
Last reviewed & updated: April 13, 2026
This notice applies to the Pell mobile application distributed on Google Play for Android devices only.
We review this Privacy Notice at least once every 12 months and update it when our processing activities change materially or when required by law.
This Privacy Notice describes how Xiangtan Pengchao Trading Co., Ltd. (“we,” “us,” or “our”) processes personal information in connection with the Pell app. We describe our practices in plain language and provide information that users and regulators commonly expect in a global privacy notice.
Controller / business: Xiangtan Pengchao Trading Co., Ltd.
Registered / principal address: No. 16, Jizi Group, Xiaohua Village, Cha’ensi Town, Xiangtan County, Xiangtan City, Hunan Province, China
General privacy and data requests: contact@pengchaoxt.com
Website: https://www.pengchaoxt.com/
We have not appointed a named individual as Data Protection Officer. Privacy and data protection functions for Pell are handled by the Privacy & Data Protection Office of Xiangtan Pengchao Trading Co., Ltd.
Data Protection Officer contact (organizational): Privacy & Data Protection Office, Xiangtan Pengchao Trading Co., Ltd., at the address above.
Email: contact@pengchaoxt.com
When you email us about privacy matters, please use the subject line DPO — Pell where helpful so we can route your request.
Pell is intended for users who are 18 years of age or older. The app does not provide an age gate or separate age-verification process beyond any age declaration you make when using the service. We do not knowingly collect personal information from anyone under 18.
Pell does not require you to create an account or log in. Use of the app is offered on the basis of your acceptance of this Privacy Notice and our Terms of Use (including any in-app acceptance screen).
Depending on how you use Pell, we may process the following categories of information (including categories often used in notices aligned with the California Consumer Privacy Act (“CCPA”) and similar laws):
We do not describe artificial intelligence, machine learning, or similar techniques in this notice unless and to the extent our product documentation explicitly states that such technologies are used.
Where the GDPR, UK GDPR, or the Swiss Federal Act on Data Protection (“FADP”) applies, we rely on one or more of the following legal bases, as appropriate:
We do not rely on “account security” as a justification for processing that implies a mandatory user account, because Pell does not use registration or login.
We do not ask you to provide government ID numbers, precise geolocation for tracking, or health data through dedicated health fields. Microphone and camera access are used only for the in-app features described in this notice and in your permission prompts. We do not use those permissions to collect additional categories of “sensitive personal information” beyond what is needed for those features; where laws such as the CPRA classify certain information as sensitive, we limit use and disclosure to providing the App and as described here.
You may request correction of inaccurate or incomplete personal information we hold about you, where applicable under the CCPA/CPRA, the GDPR (Article 16), the Colorado Privacy Act, the Connecticut Data Privacy Act, Japan’s Act on the Protection of Personal Information (“APPI”), and other laws.
To submit a correction request, email us at contact@pengchaoxt.com with the subject line Pell — Correction Request. We may need reasonable information to verify your request where permitted by law.
We retain personal information only as long as reasonably necessary for the purposes described in this notice, unless a longer retention period is required or permitted by law.
If our retention practices for a category change materially, we will update this notice and the date above.
This section supplements our notice for U.S. residents where the CCPA/CPRA, the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), the Utah Consumer Privacy Act, and similar state laws may apply.
You have the right to know whether your personal information is sold and whether it is shared (including for cross-context behavioral advertising, as “share” is defined under California law). Under the CCPA/CPRA, “sell” can include disclosures for valuable consideration, not only for cash.
To exercise a right to know regarding sale, email contact@pengchaoxt.com with the subject line Pell — Right to Know (Sale).
To exercise a right to know regarding sharing (including cross-context behavioral advertising), email us with the subject line Pell — Right to Know (Share).
You may have the right to opt out of the sale of personal information and to opt out of certain forms of sharing for cross-context behavioral advertising, where those concepts apply to our processing.
Opt-out of sale: Email contact@pengchaoxt.com with the subject line Pell — Opt-Out of Sale or Pell — Do Not Sell My Personal Information.
Opt-out of sharing / targeted advertising: Email us with the subject line Pell — Opt-Out of Sharing / Targeted Ads or Pell — Opt-Out of Sharing / Targeted Advertising. You can also limit ad personalization on your Android device using Google’s advertising settings and by resetting or limiting the use of the advertising identifier in your device settings, where available. The App does not provide a separate in-app toggle for third-party advertising beyond these device and account settings.
If you wish to use a single request covering both sale and sharing (where applicable), email contact@pengchaoxt.com with the subject line Pell — Do Not Sell or Share My Personal Information.
Where required by law and technically feasible, we will process opt-out preference signals (such as the Global Privacy Control) in line with applicable requirements for our web properties and linked flows that support such signals.
Certain laws provide rights relating to profiling that produces legal or similarly significant effects. Pell is not designed to perform automated decision-making that produces legal or similarly significant effects about you beyond ordinary app functionality. If you believe such processing applies, contact us at contact@pengchaoxt.com with the subject line Pell — Profiling Opt-Out.
Subject to exceptions under applicable law, you may also have the right to:
We will verify consumer requests where required using a verifiable consumer request process reasonable under the circumstances.
Financial incentives: We do not offer programs that require selling personal information as a condition of receiving a different price or quality of service.
We do not sell personal information in the ordinary sense of selling customer lists, and we do not use dedicated third-party advertising SDKs solely to run cross-context behavioral advertising in the App. We may use service providers (for example, Google Play billing and infrastructure) to operate the service; disclosures to those providers are described in this notice and should align with your Google Play Data safety form.
Depending on your location, you may have additional rights under:
You may lodge a complaint with a competent supervisory authority in your country or region, where such a right exists under applicable law. We do not list every authority here; contact us if you need guidance on the appropriate regulator for your situation.
For users in Japan, Korea, and South Africa, you may contact the same privacy email above regarding how service providers process information on our behalf for the purposes described in this notice.
We are located in China. If you use Pell from another country, your information may be processed in China or in other countries where we or our service providers operate. We implement appropriate safeguards as required by applicable law, which may include contractual clauses approved by regulators, where applicable. We do not claim that every jurisdiction recognizes an adequacy decision for China; we rely on permitted transfer tools and transparency.
Pell is built with Flutter/Dart. In-app purchases are processed through Google Play’s billing library. We list here only SDKs and services actually integrated in production builds; if you add analytics, crash reporting, or advertising SDKs later, update this notice and your Data safety form before release.
In-app purchases are processed by Google Play billing; Google processes payment information in accordance with Google’s terms and privacy policy.
The following descriptions match the intended use of system permissions in Pell. Final permission strings and on-screen prompts must match your released build.
We implement reasonable technical and organizational measures designed to protect personal information against unauthorized access, loss, or misuse. No method of transmission or storage is completely secure.
Pell is not directed to individuals under 18, and we do not knowingly collect personal information from children.
We may update this Privacy Notice from time to time. The “Last reviewed & updated” date at the top reflects the latest revision. Material changes will be communicated as required by law or through the app where appropriate.
Email: contact@pengchaoxt.com
Xiangtan Pengchao Trading Co., Ltd., No. 16, Jizi Group, Xiaohua Village, Cha’ensi Town, Xiangtan County, Xiangtan City, Hunan Province, China