This Privacy Policy (the "Policy") applies to your use of ReadWave (the "App"), a free mobile application providing overseas novel reading services with in-app advertisements. The App is developed and operated by PanDomain Technology Limited (hereinafter referred to as "we", "us", or "our"). We are committed to protecting the privacy and security of your personal data. This Policy sets out the types of information we collect when you use the App, the purposes and methods of processing such information, the measures we implement to protect the information, and the rights you have in respect of your personal data. By accessing or using the App, you acknowledge that you have read, understood, and unconditionally agree to be bound by the provisions of this Policy.
This Policy is incorporated into and governed by our Terms of Service. Capitalized terms not defined herein shall have the meanings ascribed to them in the Terms of Service. If you do not agree to any provision of this Policy, you must immediately cease accessing or using the App.
1. Information We Collect
We adhere to the principle of data minimization and only collect information that is necessary for providing and improving our services, fulfilling legal obligations, and protecting the legitimate rights and interests of users. The information we collect falls into the following categories:
1.1 Personal Identifiable Information (PII)
When you use specific functions of the App, we may collect the following Personal Identifiable Information ("PII"):
- Account Registration Information: When you register an account with the App, we may collect your email address, phone number, username, and encrypted password. If you register via a third-party account (e.g., Google Account, Apple ID), we will only obtain the basic user information authorized by the third party (including but not limited to user ID and nickname) in accordance with the relevant authorization agreements.
- User Support Information: When you contact our customer service for assistance, we may collect your name, contact details, and relevant communication records to respond to your inquiries and resolve the issues you have raised.
1.2 Non-Personal Identifiable Information
When you use the App, we may automatically collect non-personal information that cannot be used to identify you individually, including but not limited to:
- Device Information: Including but not limited to device model, operating system version, unique device identifiers (e.g., IMEI, Android ID, OAID, IDFA, IDFV), screen resolution, network type, device language, and storage capacity.
- Usage Data: Including but not limited to the novels you browse, search, collect, or read, reading progress, duration of App usage, interaction records with the App's functions (e.g., comments, favorites), and interaction records with in-app advertisements (e.g., ad impressions, clicks, and conversion events).
- Technical Data: Including but not limited to IP address, access time, server logs, and application package name and version number, which are used to analyze usage trends, administer the App, and enhance service stability.
1.3 Information Collected for Advertising Purposes
To provide you with relevant and personalized in-app advertisements, we may collect and process the following information (which may overlap with the information specified in Sections 1.1 and 1.2) in accordance with applicable laws and regulations:
- Advertising-related Behavioral Data: Including your browsing and reading preferences, interaction with advertisements (e.g., whether you click on an ad, the duration of ad viewing), and historical ad display records.
- Device and Network Information: As specified in Section 1.2.1, which is used to deliver ads suitable for your device, prevent ad fraud, and conduct ad effect statistics.
1.4 Information Collected via Tracking Technologies
We use cookies, beacons, tags, and similar tracking technologies to enhance your user experience and optimize the delivery of in-app advertisements. These technologies help us remember your preferences (e.g., reading settings), authenticate your account, analyze user behavior, and measure the effectiveness of advertisements. You can manage or disable cookies through your device or browser settings; however, such actions may affect the normal use of certain functions of the App, including the display of personalized advertisements.
2. How We Use Your Information
We process the collected information for the following legitimate purposes in compliance with the General Data Protection Regulation ("GDPR"), California Consumer Privacy Act ("CCPA"), and other applicable data protection laws and regulations:
- Provision and Maintenance of Free Services: Verify your identity, ensure the normal operation of the App, and provide you with free novel reading services.
- Delivery and Optimization of In-app Advertisements: Analyze your interests and preferences based on your usage behavior to deliver personalized, non-intrusive advertisements; measure ad effectiveness (e.g., impressions, clicks) to optimize ad content and delivery strategies; and prevent ad fraud and ensure the legitimacy of ad delivery.
- Improvement and Personalization of Services: Analyze user behavior and preferences to optimize the App's interface and functions, recommend novels that may be of interest to you, and customize your reading experience.
- Communication with You: Send you service-related notifications (e.g., account updates, reading progress reminders). If you have given your prior consent, we may also send you promotional information about our services or third-party partner services, which you can withdraw your consent to at any time.
- Security Assurance and Legal Compliance: Detect and prevent fraud, unauthorized access, and other illegal activities; comply with applicable laws and regulations, judicial orders, or regulatory requirements.
- Research and Analysis: Anonymize and aggregate user data for market research, service improvement, and ad effect analysis, which will not involve any Personal Identifiable Information.
3. Disclosure and Sharing of Your Information
We will not sell, lease, or otherwise disclose your personal data to any third party, except in the following circumstances:
- With Your Explicit Consent: We will only share your information with third parties after obtaining your express written consent (or other forms of explicit consent permitted by law).
- Third-party Service Providers Acting on Our Behalf:
- Advertising Service Providers: Such as ad networks, ad servers, and ad measurement providers, who need to process your relevant information to deliver, track, and optimize in-app advertisements.
- Other Service Providers: Including cloud storage providers, analytics service providers, and customer service support providers.
- Legal Requirements: We may disclose your information when such disclosure is necessary to comply with applicable laws and regulations or judicial orders.
- Protection of Rights and Interests: To protect our legitimate rights, property, or safety of users or the general public.
- Business Transfers: In the event of a merger or asset sale, your information may be transferred as part of the business assets.
4. Data Security and Protection
We implement appropriate technical and administrative measures to protect your personal data, including encryption during transmission (HTTPS) and storage, access control mechanisms, and regular security audits. However, please note that no method of transmission is 100% secure.
5. Data Retention Period
- Personal Identifiable Information: Retained for the duration of your use of the App.
- Advertising-related Data: Retained for no more than 12 months after the last interaction.
- Anonymized Data: May be retained permanently for research purposes.
6. Your Rights Regarding Your Data
Pursuant to the GDPR, CCPA, and other laws, you have the following rights: Right of Access, Right of Correction, Right of Erasure (Right to be Forgotten), Right to Restrict Processing, Right to Data Portability, Right to Object, Right to Withdraw Consent, and Right to Opt-out of Sale of Personal Data.
7. Third-Party Services and SDKs
The App may integrate third-party SDKs for advertising and analytics. These providers process information according to their own policies. We recommend reviewing their privacy terms.
8. Children's Privacy
The App is not intended for use by individuals under the age of 13. We do not intentionally collect personal data from minors.
9. Cross-Border Data Transmission
Your data may be transferred outside your country. We ensure such transfers comply with applicable laws, using Standard Contractual Clauses (SCCs) where necessary.
10. Changes to This Policy
We may update this Policy from time to time. Material changes will be notified via the App at least 7 days prior to the effective date.