Last updated: September 21, 2024
This privacy policy (this “Privacy Policy”)
explains how Charmnovels and our Affiliates (“we”, “our” or “us”) collect, use and
disclose your personal data. This Privacy Policy applies to Charmnovels (“Platform”) and
related services (collectively, our “Services”), which informs you of our policies
regarding the collection, use, and disclosure of personal data when you use our Services
and the choices you have associated with that data.
By downloading, accessing, using
and/or interacting with our Services, you fully understand about our collection, use and
disclosure of your personal data as described in this Privacy Policy. This Privacy Policy
is incorporated by reference into the end user license agreement available at Terms of
Service (the “EULA”) and is subject to the provisions of the EULA. Capitalized terms used
but not defined in this Privacy Policy shall have the meaning ascribed to such terms in
our EULA.
This Privacy Policy will help you to understand:
What Personal Data We
Collect and How We Use
Cookies and Similar Technologies
How We Entrust A
Third-Party to Process, Share, Transfer and Disclose Your Personal Data
How Long We
Keep Your Personal Data
The Security of Your Personal Data
Children
Your
Rights
Changes
Addendum
Contact Us
1. What Personal Data We Collect
and How We Use
We provide various articles created based on users' shopping
experiences and impressions. You can access our service without registering or logging in.
Certain products on our website are controlled by third parties, including third parties
located outside the EU/EEA, which shall be borne by its own privacy policy respectively.
We collect and process your personal data only to the minimum extent necessary to achieve
the following purposes, based on appropriate legal grounds.
1.1
In order to
provide some location-based services such as forming a team with people nearby, we may
collect your IP address, GPS, RFID, your home address.
The processing activity for
this purpose is based on your consent. We will ask for your consent when you turn on this
feature and you have the right to withdraw your consent at any time.
1.2
To
improve our services and correct errors that occur during your use, we may collect
relevant information while you browse our platform, including but not limited to your
behavioral data, device information, and network status.
The processing activity for
this purpose is based on our legitimate interests and will not override your legal rights
and interests.
1.3
In order to comply with applicable law (such as anti-money
laundering regulations), we may collect your device and network information.
The
processing activity for this purpose is necessary for compliance with the legal obligation
we subject to.
2. Cookies and Similar Technologies
We use cookies and other
similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to
enhance your experience using the Services. Cookies are small files which, when placed on
your device, enable us to provide certain features and functionalities.
You have the
option to permit installation of such Cookies or subsequently disable them. You may accept
all cookies, or instruct the device or web browser (as applicable) to provide notice at
the time of installation of cookies, or refuse to accept all cookies by adjusting the
relevant cookie retention function in your device. However, in the event that you refuse
to install cookies, your browsing experience may be interrupted.
3. How We Entrust a
Third-Party to Process, Share, Transfer and Disclose Your Personal Data
We may share
your personal data with the following categories of third parties in order to provide our
Services to you
3.1 Affiliates
We are a global company and has affiliates all
over the world. In order to provide our Services, we will share your personal data with
our affiliates based on the respective legal basis and data processing agreements signed
between us.
3.2 Advertising
This type of service allows User Data to be utilized
for advertising communication purposes displayed in the form of banners and other
advertisements on this Website, possibly based on User interests.
This does not mean
that all Personal Data are used for this purpose. Information and conditions of use are
shown below.
Some of the services listed below may use Cookies to identify Users or
they may use the behavioral retargeting technique, i.e. displaying ads tailored to the
User's interests and behavior, including those detected outside this Website. For more
information, please check the privacy policies of the relevant services.
In addition
to any opt out offered by any of the services below, the User may opt out of a third-party
service's use of cookies by visiting the Network Advertising Initiative opt-out page .
(1)AdSense:
-
Google
AdSense is an advertising service provided by Google Inc. This service uses the
"Doubleclick" Cookie, which tracks use of this Website and User behavior concerning ads,
products and services offered.
-
Users may decide to disable all the Doubleclick
Cookies by clicking on: google.com/settings/ads/onweb/optout
-
Personal Data
processed: Cookies; Usage Data
-
Place of processing: Ireland - Privacy Policy -
Opt Out
3.3 Data Analytics
In order to better understand and provide more
effective services, we may conduct research and analysis on the collected personal data,
such as your behavior data on our platform. We may analyze, categorize, and segment this
personal data. The research and analysis may be presented on an aggregate basis.
We
may also use third-party Service Providers to monitor and analyze the use of our Service.
These third parties have access to your Personal Data only to perform these tasks on our
behalf and are obligated not to disclose or use it for any other purpose. For more
information, please visit the privacy policies of the partners found here:
(1)Google
Analytics:
-
Google Analytics is a web analysis service provided by Google Inc.
("Google"). Google utilizes the Data collected to track and examine the use of this
Website, to prepare reports on its activities and share them with other Google
services.
-
Google may use the Data collected to contextualize and personalize
the ads of its own advertising network.
-
Personal Data processed: Cookies;
Usage Data
-
Place of processing: Ireland - Privacy Policy - Opt Out
(2)Google
Tag Manager:
-
Google Tag Manager is a tag management service provided by Google
Ireland Limited.
-
Personal Data processed: Usage Data.
-
Place of
processing: Ireland - Privacy Policy.
3.4 Remarketing and behavioral targeting
This
type of service allows this Website and its partners to inform, optimize and serve
advertising based on past use of this Website by the User.
This activity is
facilitated by tracking Usage Data and by using Trackers to collect information which is
then transferred to the partners that manage the remarketing and behavioral targeting
activity.
Some services offer a remarketing option based on email address lists.
In
addition to any opt-out feature provided by any of the services below, Users may opt out
by visiting the Network Advertising Initiative opt-out page .
Users may also opt-out
of certain advertising features through applicable device settings, such as the device
advertising settings for mobile phones or ads settings in general.
(1)Google Ads
Remarketing (Google Ireland Limited)
-
Google Ads Remarketing is a remarketing
and behavioral targeting service provided by Google Ireland Limited that connects the
activity of this Website with the Google Ads advertising network and the DoubleClick
Cookie. Users can opt out of Google's use of cookies for ads personalization by visiting
Google's Ads Settings .
-
Personal Data processed: Cookies; Usage Data.
-
Place
of processing: Ireland - Privacy Policy - Opt Out .
(2)Remarketing with Google
Analytics (Google Ireland Limited)
-
Remarketing with Google Analytics is a
remarketing and behavioral targeting service provided by Google Ireland Limited that
connects the tracking activity performed by Google Analytics and its Cookies with the
Google Ads advertising network and the Doubleclick Cookie.
-
Personal Data
processed: Cookies; Usage Data.
-
Place of processing: Ireland - Privacy Policy
- Opt Out .
3.5 Traffic optimization and distribution
This type of service
allows this Website to distribute their content using servers located across different
countries and to optimize their performance.
Which Personal Data are processed
depends on the characteristics and the way these services are implemented. Their function
is to filter communications between this Website and the User's browser.
Considering
the widespread distribution of this system, it is difficult to determine the locations to
which the contents that may contain Personal Information of the User are transferred.
(1)Cloudflare
(Cloudflare Inc.)
-
Cloudflare is a traffic optimization and distribution
service provided by Cloudflare Inc.
-
The way Cloudflare is integrated means
that it filters all the traffic through this Website, i.e., communication between this
Website and the User's browser, while also allowing analytical data from this Website to
be collected.
-
Personal Data processed: Cookies; various types of Data as
specified in the privacy policy of the service.
-
Place of processing: United
States - Privacy Policy.
3.6 Law enforcement / legal obligation
(1) Anti-cheat
and anti-fraud companies
We may share the information required for detecting,
investigating, and preventing cheating on the platform and violations of the End User
License Agreement, solely for the purposes of detecting, investigating, and preventing
violations on the platform.
(2) Public authorities and auditors
Some personal
data shall be disclosed to public authorities, e.g., tax and customs authorities,
auditors, and other competent parties in accordance with the applicable laws.
3.7
Sale or merger
A third party that acquires all or substantially all of us or our
business. We may disclose information to a third party in the event that we sell or buy
any business or undergo a merger, in which case we will disclose your data to the
prospective buyer of such business. We may also disclose information to a third party if
we sell, buy, merge or partner with other companies or businesses, or sell some or all of
our assets. In such transactions, personal data may be among the transferred assets. You
will be notified via email, in-app/in-game notice and/or notice on our website of any
change in ownership or users of your personal data.
4. How Long We Keep Your Personal
Data
4.1 How we determine
We determine the retention period of your personal
data taking consideration of the following elements:
period of the contractual
relationship with you;
sensitivity of the personal data;
time elapsed since your
last interaction with us;
security reasons;
applicable statutes of
limitation;
ongoing or potential litigation or dispute;
regulatory or legal
obligation to retain the personal data.
4.2 How long we keep your personal data
We
may retain most of your personal data as long as needed to provide services or products to
you, or as required or permitted by applicable laws.
When destroying personal data,
measures will be taken to make the personal data irrecoverable or irreproducible, and
electronic files which contain personal data will be deleted permanently using a technical
method which makes the files irreproducible.
In the event that the processing and
retention period have terminated, but personal data is required to be retained
continuously for other reasons including but not limited to for the purposes as prescribed
under applicable laws, the relevant personal data will be stored and maintained separately
from other types of personal data. If you require us to destroy your personal data before
the end of its life cycle (as set out in the retention policy above), we will destroy your
personal data in accordance with local laws.
5. The Security of Your Personal Data
We
are committed to maintaining the privacy and integrity of your personal data no matter
where it is stored. Our group companies have information security and access policies that
limit access to our systems and technology. We also protect data through the use of
technological protection measures such as encryption. Your personal data will remain
subject to our technical and organizational controls and our policies and procedures
(including but not limited to this Privacy Policy).
Unfortunately, the transmission
of information via the internet is not completely secure. Although we will use
commercially reasonable efforts to protect your personal data, we cannot guarantee the
security of the information transmitted to our services; any transmission of your
information is at your own risk.
In the case of a personal data breach, we will
notify the personal data breach to the supervisory authority competent, where feasible,
not later than 72 hours after having become aware of it, unless the personal data breach
is unlikely to result in a risk to the rights and freedoms of you. When the personal data
breach is likely to result in a high risk to the rights and freedoms of you, we will
communicate the personal data breach to you without undue delay.
6. Children
You
hereby represent that you are an “adult” (as defined in the applicable in your
jurisdiction) and have the requisite power and authority to access and/or use our
Services. If you are not an adult, you must obtain the consent of your parent or legal
guardian to use the Services. Usually our Services are not intended for children under the
age of 16(this age requirement may vary in your country and is set forth in the table
below) and we do not knowingly collect any personal data from such children. Children
under the age of 16 should not use or attempt to use our Services, and if you are under
16, please do not attempt to use our Services.
In the event that we learn that we
have inadvertently gathered personal data from a child under the age of 16, we will take
reasonable measures to delete such information from our records. Parents who believe that
we might have gathered any information from or about a child under the age of 16 may
submit a request to the email address set forth in the section “Contact Us” below.
7.
Your Rights
7.1 The right to be informed
You have the right to be provided with
clear, transparent and easily understandable information about how we use your personal
data and your rights. This is why we are providing you with the information in this
Policy.
7.2 The right of access
You have the right to obtain access to your
personal data. This is so you are aware and can check that we are using your personal data
in accordance with applicable data protection laws. Please contact us and submit a request
to the email address set forth in the section “Contact Us” below.
7.3 The right to
rectification
You have the right to rectify your personal data if it is inaccurate or
incomplete. If you believe that we hold any other personal data about you that is
inaccurate, you can change the information you are able to modify in the corresponding
settings. For information that you cannot change, please contact us via email.
7.4
The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple
terms, enables you to request the deletion or removal of your personal data where there is
no compelling reason for us to keep using it. This is not an absolute right to erasure and
exceptions apply.
You may request that we erase the personal data we hold about you
in the following circumstances:
you believe that it is no longer necessary for us to
hold such personal data; or
you believe the personal data we hold about you is being
unlawfully processed by us.
We may need to retain personal data if there are valid
grounds under data protection laws for us to do so (e.g., for the defense of legal claims
or freedom of expression) but we will let you know if that is the case. Where you have
requested that we erase personal data that has been made available publicly on the
Services and there are grounds for erasure, we will use reasonable steps to try to tell
others that are displaying the personal data or providing links to the personal data to
erase it too.
You can also exercise your right to restrict our processing of your
personal data (as described below) whilst we consider your request.
7.5 The right to
restrict processing
You have a right to require us to stop processing the personal
data we hold about you other than for storage purposes in certain circumstances. Please
note, however, that if we stop processing the personal data, we may use it again if there
are valid grounds under data protection laws for us to do so (e.g., for the defense of
legal claims or for another’s protection). As above, where we agree to stop processing the
personal data, we will try to tell any third party to whom we have disclosed the relevant
personal data so that they can stop processing it too.
You may request we stop
processing the personal data we hold about you where:
you believe the personal data
is not accurate for the period it takes for us to verify whether it is accurate;
you
wish to erase the personal data as the processing we are doing is unlawful but you want us
to retain the personal data but just store it instead; or
you wish to erase the
personal data as it is no longer necessary for our purposes but you require it to be
stored for the establishment, exercise or defense of legal claims.
7.6 The right to
data portability
You have rights to obtain and reuse your personal data for your own
purposes across different services. For example, if you decide to switch to a new
provider, this enables you to move, copy or transfer your personal data easily between our
IT systems and theirs safely and securely, without affecting its usability.
7.7 The
right to object to processing
You have the right to object to certain types of
processing, including processing for direct marketing (which we perform only with your
consent).
7.8 The right to lodge a complaint
You have the right to lodge a
complaint about the way we handle or process your personal data with your national data
protection authority.
7.9 The right to withdraw consent
If you have given your
consent to anything we do with your personal data, you have the right to withdraw your
consent at any time (although if you do so, it does not mean that anything we have done
with your personal data with your consent up to that point is unlawful). This includes
your right to withdraw consent to us using your personal data for marketing purposes.
7.10
The right not to be subject to automated decision making
You have the right not to be
subject to a decision based solely on automated processing (including profiling) which
produces legal (or similarly significant) effects to you.
We usually act on requests
and provide information free of charge, but may charge a reasonable fee to cover our
administrative costs of providing the information for:baseless or excessive/repeated
requests; or further copies of the same information. Alternatively, we may be entitled to
refuse to act on the request.
Please consider your request responsibly before
submitting it. We will respond as soon as we practically can, generally within one month
from when we receive your request but, if the request is going to take longer to deal
with, we will come back to you and let you know.
We will also cooperate with the
third-parties who have data interaction with us to ensure your rights pursuant to
applicable laws and regulations.
8. Changes
If we make any material changes to
this policy, we will post the updated policy here and notify our users. Please check this
page frequently to see any updates or changes to this policy.
9. Addendum
9.1
Brazil Addendum
If you are located in Brazil, you acknowledge that we are bound by
the Brazil’s General Data Protection Law (Lei Geral de Prote??o de Dados Pessoais, LGPD).
If you have any questions, concerns or complaints about this Privacy Policy, or how we
handle your Personal Data, please contact us at the as shown in section “Contact Us”
below.
9.2 Columbia Addendum
If you are located in Columbia, you acknowledge
that we are bound by the Statutory Law 1581 of 2012 (Law 1581). If you have any questions,
concerns or complaints about this Privacy Policy, or how we handle your Personal Data,
please contact us at the address as shown in section “Contact Us” below.
9.3 Turkey
Addendum
If you are located in Turkey, you acknowledge that we are bound by the Law
on Protection of Personal Data, Law No. 6698 (LPPD). If you have any questions, concerns
or complaints about this Privacy Policy, or how we handle your Personal Data, please
contact us at the address as shown in section “Contact Us” below.
9.4 Peru
Addendum
If you are located in Peru, you acknowledge that we are bound by The
Personal Data Protection Law N° 29733 (PDPL) and the Supreme Decree N°
003-2013-JUS-Regulation of the PDLP (Regulation). If you have any questions, concerns or
complaints about this Privacy Policy, or how we handle your Personal Data, please contact
us at the address as shown in section “Contact Us” below.
10. Contact Us
If you
want to lodge a complaint about how we handle your personal data, or need to contact us
for any other reason (including exercising any rights related to the above personal data),
please send your request to:[email protected]
PRIVACY POLICY