Privacy

Privacy Policy

Last updated: 2026-11-03

RedSugarTree ("we", "us", "our") operates the website at redsugartree.com (the "Site"). This Privacy Policy explains what information we collect through the Site, why we collect it, who we share it with, how long we keep it, and what rights you have over it.

We collect very little information, and only what you give us or what is needed to serve the page you requested. The Site does not use advertising cookies, does not run behavioural advertising, does not build behavioural profiles, and does not sell or share personal information to third parties for their own purposes.

1. Who we are (data controller)

*The operator is a natural person acting for purposes outside his trade or profession, and is not presenting himself as an "entrepreneur".*

*Note on the Spanish-language version: the "NIF / CIF" (Spanish tax identification number) field reads "No aplica — el operador no está establecido en España". See the Legal Notice, Section 1, for the reasoning.*

2. Scope of this Policy

This Policy applies to the Site and to our project update emails. It does not apply to SoloDesk, which is a project still under development and is not available to anyone at this time — see Section 3.

3. SoloDesk is a project in development

SoloDesk is a software project that is still being built. It is not finished, it is not distributed, and it is not available to use, download, or buy. Nothing on the Site is an offer to sell, a contract, or a commitment to deliver any product or service.

4. Information we collect

The table below describes what we collect when you subscribe to project updates. We collect only what you give us or what is needed to serve the page you requested.

We do not collect special categories of personal data, financial information, government identifiers, precise location, health data, or any content you submit other than your email address. We do not ask for and do not want additional personal information.

Availability by region: the project update subscription is not currently open to users located in mainland China. If you are located in mainland China, please write to us at [email protected] instead of subscribing.

5. Why we collect it, and our legal bases

Where we rely on legitimate interests, our interest is the operation and security of the Site and the (limited) improvement of our own project. We have assessed that these do not override your rights, given that we collect no special category data, we do not profile you, and we do not use automated decision-making that produces legal or similarly significant effects (Art 22).

6. Consent and how to withdraw it

Your consent is captured when you tick the consent box in the subscription form and confirm via the link in the email we send you. We record the time, the version of the consent text you accepted, the specific thing you agreed to (project updates about SoloDesk), and the fact that you confirmed. We must be able to demonstrate that you consented (Art 7(1)), so we keep that record.

You may withdraw consent at any time:

• by clicking the unsubscribe link in any email we send;
• by emailing [email protected] with the subject "unsubscribe".

Withdrawal costs nothing and takes effect immediately for all future project update email. Once we have received your withdrawal we keep a minimal record that you opted out (so we do not contact you again) — see Section 8.

7. Recipients, processors, and international transfers

7.1 Who processes data on our behalf

We do not disclose personal information to advertisers, data brokers, or analytics companies that profile users across websites. We do not sell personal information. We do not share personal information for cross-context behavioural advertising.

7.2 International transfers

All of the recipients above are located in the United States, outside the European Economic Area and the United Kingdom. No copy of your personal information is stored in the EEA or the UK. Where personal information from the EEA, the UK, Switzerland or Japan is transferred, we rely on an adequacy decision where one exists, and otherwise on the European Commission's Standard Contractual Clauses (Decision 2021/914) together with a transfer impact assessment. You may request a copy of the applicable safeguards by writing to [email protected].

The project update subscription is not currently open to users located in mainland China, so we do not transfer personal information of users in mainland China outside mainland China through this Site.

7.3 Cookies and similar technologies

The Site does not set any cookies for advertising, analytics, or cross-site tracking, and it does not use fingerprinting or similar techniques. Your language preference is stored in your browser's localStorage, which is not a cookie and is not transmitted to us unless you submit the subscription form. Any usage measurement we perform is first-party, aggregated, and does not set a cookie or build a profile of you.

If this changes, we will update this Section before the change takes effect, and where the law requires it we will ask for consent before setting any non-essential technology.

7.4 Analytics

We do not use third-party analytics. We keep aggregate, non-identifying counts of how the Site is used so that we can improve it. These counts cannot be traced back to an individual device or person, and we do not use them to build a profile of you.

8. How long we keep your information

9. Your rights

9.1 EEA, UK and Switzerland (GDPR / UK GDPR)

You have the right to:

• access your personal information (Art 15);
• rectify inaccurate data and complete incomplete data (Art 16);
• erase your data ("right to be forgotten") (Art 17);
• restrict processing in certain circumstances (Art 18);
• object to processing based on legitimate interests, including direct marketing (Art 21) — you can object at any time and we will stop;
• receive your data in a portable format (Art 20);
• withdraw consent at any time (Art 7(3)), without affecting the lawfulness of processing before withdrawal;
• not be subject to solely automated decisions with legal or similarly significant effects (Art 22) — we do not do this.

You also have the right to lodge a complaint with your local supervisory authority. For the EU, you can find your authority via the European Data Protection Board's website; for the UK, the Information Commissioner's Office (ico.org.uk).

Where we rely on consent, you can withdraw it as described in Section 6. Where you ask us to erase data, we will delete it, except where we must keep it — for example, records required by law, or the minimal suppression record described in Section 8, which we retain in order to honour your withdrawal.

We aim to respond within 30 days and in any event within the period required by applicable law.

9.2 Japan (APPI)

Subject to the conditions in the Act on the Protection of Personal Information, you may request disclosure of your retained personal data, correction of inaccurate data, and suspension of use or deletion. We handle requests free of charge and in writing, in English or Japanese. You may also complain to the Personal Information Protection Commission (PPC) of Japan. Requests in Japanese should be sent to [email protected].

9.3 Mainland China (PIPL)

The project update subscription is not currently open to users located in mainland China, so we do not collect personal information from users in mainland China through this Site, and the cross-border transfer provisions of the PIPL do not apply to the Site as it currently operates.

If that changes, we will update this Section before it changes, and we will obtain your separate consent and provide the information required by Article 39 of the Personal Information Protection Law — the name and contact details of the overseas recipient, the processing purpose, the processing method, the categories of personal information, and how you exercise your rights against that recipient.

Where you have asked us to do something and we hold personal information about you in order to do it, you may ask us to confirm and explain our processing of it, request a copy of it, correct it, delete it, withdraw your consent, and request a portable copy in a structured, commonly used format. You may also complain to the network operator or the competent department in your locality. We handle requests within the timeframe required by applicable law and respond in Chinese. Send requests to [email protected].

9.4 California (CCPA/CPRA)

Where the CCPA/CPRA applies to us, California residents have the right to know what personal information we collect and how we use and disclose it, the right to delete, the right to correct, the right to opt out of sale or sharing of personal information, the right to limit use of sensitive personal information, and the right to be free of discrimination for exercising these rights. We do not sell personal information and we do not share it for cross-context behavioural advertising, so there is nothing for you to opt out of in practice. Requests can be made to [email protected]. We do not charge for processing requests and we do not sell or share your personal information in exchange for a benefit.

9.5 Spain (LSSI / LOPDGDD)

You may lodge a complaint with the Agencia Española de Protección de Datos (www.aepd.es). Requests in Spanish should be sent to [email protected].

10. What happens if we do not get what we need

The only information we need from you is a working email address. Without it we cannot send you the confirmation email and you cannot subscribe. If you do not confirm your subscription, we delete the address after the period in Section 8.

11. Security

We use HTTPS/TLS for data in transit, encryption at rest at our email and database providers, and access limited to the person who operates the Site. We do not export raw list data outside the sending service.

No system is completely secure. If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority within 72 hours of becoming aware of it (GDPR Art 33), and will notify you without undue delay where the risk is high (Art 34).

12. Automated decision-making and profiling

We do not use automated decision-making within the meaning of GDPR Art 22 and we do not profile you. We do not build audiences, segments or lookalike audiences, and we do not use your data to target advertising.

13. Children's privacy

The Site is not directed to children under 13 and we do not knowingly collect personal information from children under 13. We apply a threshold of 16: we do not knowingly collect personal information from anyone under 16 without the consent of a parent or guardian. If you believe a child has provided us with personal information, contact us at [email protected] and we will delete it.

14. Third-party links

The Site may link to external websites we do not control. We are not responsible for their content, their privacy practices, or how they handle your data. Please read their own privacy policies. A link does not imply endorsement.

15. International operation of this Site

The Site is operated by Gu Shan. It is intended for a global audience, which means it may be accessed from the European Economic Area, the United Kingdom, Switzerland, Japan and elsewhere. We apply a single, high standard of data protection to all users, regardless of where they are.

16. Changes to this Policy

We will update this Policy when our practices change or when the law requires it. If a change materially affects your rights, we will notify you by email before the change takes effect. We will record the version of this Policy and the version of each consent text you accepted.

17. Contact us and complaints

If you are unsatisfied with our response, you may escalate to your local supervisory authority (see Section 9).