Privacy Policy

Last Updated: October 1, 2022

This Privacy Policy (hereinafter referred to as “Policy”) is aimed at assisting you to understand the privacy details about how NovelUP (hereinafter referred to “NovelUP” and “We”) manages the Personal Data you provide to NovelUP while using our products or services, including how NovelUP collects, processes and transmits your Personal Data, etc.

Once you use our products or services, you shall be deemed to have read, agreed and accepted all terms and conditions stated in this Policy as well as all the changes we have made at any time. NovelUP respects and protects your personal privacy. Please read carefully and understand this Policy before providing or allowing your personal data be collected by NovelUP.

1. How NovelUP collects and uses your Personal Data

NovelUP collects data that you make available to us voluntarily through our interactions with you and through our services for a variety of purposes described below,including operating effectively and providing you with the best experiences with our services.

1.1 Data you give us

You may provide us data in different ways. For example, we collect and store data that you give us when you register a user profile. The data that you give us includes:

Profile data. This includes your Google/Facebook account, nickname and profile picture. You may optionally provide additional data on your Profile.

To become a user of our services, you will need to provide a Google/Facebook account to log in. If you only need to use the browsing and search services, you do not need to register as a user or provide the above data. If you choose not to provide this data, you may not be able to register your account properly, but this will not affect your ability to use other features of this product. You may provide us with your nickname and profile picture during the registration process, but refusal to provide this data will not affect your ability to enjoy other functions of this product.

Feedback data. You can give us feedback on problems you are experiencing with the product in the feedback interface of NovelUP. During this process, we collect data about your most recent actions and the content of the messages you send us, such as feedback, survey data and product reviews that you write.

1.2 Data we collect about you

We collect data through a variety of sources. With regard to your use of our Services we may automatically collect the following data:

Navigation data. We collect data about how you navigate and use our Services, such as the types of content you view or engage with. In detail, we will collect your search records to show your search history, your reading records to give you access to your reading history and follow up from last time, your download records to show you offline books, and your library addition records to show you library pages.

Device data. We collect data from or about your devices where you install or access our Service, which helps us provide consistent Services across your devices. Device data may include; data about your operating system, hardware version, type and model, server IP address and server serial number. Please understand that this data is essential for us to provide our services and to ensure the proper functioning of our products.

2. How we store your Personal Data

The data collected by NovelUP will be stored in a secure database. We will ensure that your Personal Data is adequately protected through technical measures such as anonymisation and encrypted storage. Currently, we don't process your Personal Data across borders. However, if we need to transfer your Personal Data across borders in the future due to business development, we will do so in accordance with applicable laws and regulations.

With respect to retention period, we will only retain your Personal Data for as long as necessary to achieve the purposes described in this policy, unless there is a mandatory retention requirement by law. Specifically, we determine the retention period by reference to the following criteria:

a)to fulfil the business and service purposes relating to you in response to any inquiries or complaints you may have.

b)to ensure the security and quality of services we provide to you.

c)the existence of other special agreements or legal and regulatory requirements regarding the retention period.

After the retention period has expired, we will delete or anonymize your Personal Data as required by applicable law.

 

3. How NovelUP disclose your Personal Data

Under the relevant applicable laws, NovelUP may disclose your Personal Data under the following situations:

a)NovelUP has obtained your express consent for the disclosure of data and will only disclose it to the extent that you have consented.

b)For the purposes stated in this Privacy Policy only, we may share your Personal Data with our suppliers, service providers, consultants or agents for the purpose of providing basic customer service. These suppliers, service providers, consultants or agents provide us with technical infrastructure services, analyze how our services are used, measure the effectiveness of advertising and services, provide customer service and payment services, conduct academic research and surveys, or provide legal, financial and technical advisory services. NovelUP will conduct a prior review of the data security capabilities of vendors, service providers, consultants or agents before data is disclosed.

c)To the extent permitted by law or regulation, NovelUP may disclose your Personal Data under other circumstances where such disclosure is required for universal justice as deemed by NovelUP. Such circumstances include the disclosure to prevent personal injury or death, to avoid significant property loss or to protect the social public interest.

d)In order to execute or to assist in executing some legal or administrative procedures, NovelUP may provide your Personal Data to the relevant law enforcement agencies or government sectors.

4. Cookies and SDK

4.1 Cookie technology

A cookie is a neutral technology that allows a web server to store data on or read from a client. Cookies are text-based, encrypted files that contain information about a user's visit to a website.

NovelUP uses secure cookie technology to provide you with a more convenient service. We use cookies for the following purposes in general;

a)Preferences: Cookies can help us provide services to you in accordance with the personalized settings of the service style and appearance you want. The cookie records the font size, resolution and other factors ​​you set before, so that it can be automatically adjusted to the previous settings when you visit again.

b)Security: Cookies help us to keep our data and services secure and to detect hacking, fraud and other activities against our products and services.

c)Efficiency: Cookies help to avoid unnecessary server load and improve service efficiency.

d)Analysis and research: Cookies can help us understand and improve our products and services also provide reference data for the development of new functions or new products.

e)Advertising optimisation: Cookies can improve the attractiveness of advertising to users and increase the value of advertising services to advertisers and publishers.

4.2 Third-party SDKs

In order to ensure the implementation of NovelUP's relevant functions and the safe and stable operation of the application, we may authorise our partners to provide some of the services to you (in particular, we may access third party software development kits (SDKs) from these authorised partners to implement the relevant functions or services and share with these third parties the data necessary to implement the functions or services). Please note that we will only share your Personal Data for lawful, legitimate, necessary, specific and explicit purposes and only to the extent necessary to provide the service. We will use our commercially reasonable efforts to require these partners to comply with relevant confidentiality and data security obligations.

5. Security measures NovelUP take to protect your Personal Data

We will provide security measures to NovelUP users. We will take reasonable and practicable measures to protect your Personal Data that we collect and prevent your Personal Data from being accessed, tampered with, disclosed or destroyed by unauthorized third parties. For example, when you access NovelUP account, we have a user validation procedure or password retrieval procedure to ensure the security of your account.

In addition, there are duties of confidentiality in the contract signed between NovelUP and its partners. If a partner breaches the confidentiality obligation in the contract and brings about losses to the obligee, NovelUP will impose legal liabilities on the partner and terminate the business relationship with the partner.

There is no absolutely safe website, internet transmission, computer system and wireless connections. Except the necessary protective measures we have taken, users have to strengthen the awareness of privacy security risks. For example, when skipping to third party websites, links, products or services through our services, please carefully read through the terms and conditions or privacy policies of such websites, links, products or services regarding the security of the data and information collected by them. NovelUP shall not be liable for any actions you make thereof. If you find certain contents, advertisements, or functions in our products or services that may be possibly provided by third parties, and may possibly endanger your privacy and security, please contact NovelUP at novelupread@gmail.com and we will handle that priority.

6. How to access, modify and delete your Personal Data

As the user of the products or services, you are obliged to ensure the completeness and accuracy of the Personal Data you provide and carefully keep your Personal Data safe. We will protect and update your Personal Data on time and try our best to ensure your normal use of the products and services.

In accordance with your rights under relevant applicable law, you may exercise:

a)right of access, i.e. the right to have access to your Personal Data held by NovelUP and to know whether your Personal Data is being processed or not. You can view your search history on the search page, your reading history on the reading history page, your bookshelf additions and downloads on the bookshelf page, and your account information and interaction history on your Profile page.

b)right to rectification, i.e. the right to request rectification of the inaccurate Personal Data we hold concerning you. Because you control your Profile, these details are available to you at any time by accessing your “Profile” page, which gives you the chance to correct or update your data at any time by logging in to NovelUP.

c)right to erasure, i.e. the right to request us to Erase personal Data Personal Data concerning you. You can choose to clear your search history in the Search History area, and delete your read history, bookshelf additions history and download history in the Bookshelf History area.

d)right to restriction of processing, i.e. the right to restrict our processing of your Personal Data;

e)right to object, i.e. the right to object to our processing of your Personal Data;

f)right to data portability, i.e. the right to request us, where technically feasible, to have your Personal Data transmitted to another data controller.

To request exercising your rights under the applicable law, please fill out the form attached to this Policy and send to us via email at novelupread@gmail.com. After receiving your request, we will process within the period of time as prescribed by applicable law.

While you are exercising your rights under the applicable law, we may investigate the legality and rationality of your request. If we have reasonable grounds or suspect that your request is deceptive, repetitive or infringes upon the rights and freedom of third parties, or if we are unable to get through the investigation, we may ask you to provide further data or may refuse to process your request.

7. How NovelUP process Personal Data of Children

NovelUP understands the importance of safeguarding the Personal Data of children.

Our products, websites and services are mainly for adults. If you are a minor, please ask your parents or other guardians to read this policy carefully and use our services or provide us with data with the consent of your parents or other guardians.

As to the disclosure of the Personal Data of a minor, we will provide, in principle, only when permission is given by his/her legal guardian, or where the law or relevant government sector legitimately requires. In addition, if you find that a minor sends his or her us the consent of his or her guardian, please fill out the form attached to this Policy and send to us via email at novelupread@gmail.com. We will reply to you in time.

8. Update of this Policy

NovelUP reserves the right to modify this Policy. These revisions form part of this policy.

By continuing to use NovelUP products and services, you are agreeing to be bound by the revised Privacy Policy.

If this Policy is modified, NovelUP will publish the latest policy in App.

9. How to contact NovelUP

NovelUP has appointed a Data Protection Officer. For any questions in relation to the protection of personal privacy, please contact our Data Protection Officer by filling out the form attached to this Policy. Send the completed form to our email address, novelupread@gmail.com.

Feedback Form for Personal Data and Privacy Questions.docx