This Privacy Policy ("Policy") governs the collection, use, storage, disclosure, and protection of personal data collected by FUNAI TECHNOLOGY PTE. LTD. ("we", "us", "our"), a company incorporated in Singapore with its registered address at 6 RAFFLES QUAY #14-02, Singapore, 048580, SG. This Policy applies to our mobile application FunFlow ("App"), which primarily provides novel and comic drama content services.
This Policy is formulated in strict compliance with the Personal Data Protection Act 2012 (PDPA) of Singapore. By accessing or using the App, you (the "User") consent to the collection, use, disclosure, and protection of your personal data in accordance with the terms and conditions set out in this Policy. If you do not agree to any provisions of this Policy, please cease using the App immediately.
1. Definitions
- Personal Data: Any information, whether true or not, that can be used (either directly or indirectly) to identify an individual, including but not limited to personal identification information, contact information, and usage records.
- User: Any individual who accesses, browses, registers, or uses the services provided by the FunFlow App.
- App Services: The novel reading, comic drama viewing, and related auxiliary services provided by the FunFlow App operated by us.
- PDPA: The Personal Data Protection Act 2012 of Singapore and its relevant amendments and supporting regulations.
- Data Protection Officer (DPO): The person responsible for overseeing our compliance with the PDPA, handling data-related inquiries and complaints, and managing data protection risks.
- Third-Party Service Providers: Institutions or individuals engaged by us to assist in providing App services, such as technical support, payment processing, and content distribution.
2. Personal Data We Collect
We collect personal data in accordance with the principles of legality, fairness, necessity, and transparency, and only collect data that is necessary for providing App services. The collection methods and specific types of personal data are as follows:
2.1 Personal Data Provided Voluntarily by You
- Account Registration and Profile Information: When you register an account on the App, you may need to provide a username, email address, password, and optional profile information (such as nickname, avatar, gender, age, and content preferences). This information is used to create and manage your account, and to personalize your service experience.
- Contact Information: When you contact our customer service for help, feedback, or complaints, you may provide your email address, phone number, or other contact details, which we use to respond to your inquiries and resolve related issues.
- Payment Information: If you purchase paid content (such as premium novels, exclusive comic dramas) or value-added services within the App, you may need to provide payment-related information (such as credit card details, e-wallet account information). This information is only used for processing payment transactions and verifying payment validity, and we will not store sensitive payment details unless required by law.
- User-Generated Content: When you post comments, reviews, or other content (such as likes, shares, and feedback) on the App, we will collect such content to display it on the App and improve our service quality.
2.2 Personal Data Collected Automatically
When you use the App, we may automatically collect certain personal data through technical means, including but not limited to:
- Device Information: Device type, operating system version, unique device identifier (such as IMEI, Android ID), IP address, mobile network information, and device hardware configuration. This information is used to ensure the normal operation of the App, optimize service compatibility, and prevent fraudulent activities.
- Usage Data: Records of your activities on the App, including content viewed (novels, comic dramas), reading/watching duration, browsing history, search keywords, collection records, and interaction behaviors (likes, comments, shares). This information is used to analyze user preferences, provide personalized content recommendations, and improve the App's content and functions.
- Location Information: We may collect general location information (such as country, region) based on your IP address or device location settings, but we will not collect precise location information unless you explicitly authorize it. This information is used to provide region-specific content recommendations and comply with local regulatory requirements.
- Cookies and Similar Technologies: We use cookies, web beacons, and other similar technologies to collect information about your use of the App, such as login status, browsing preferences, and service usage frequency. This helps us remember your settings, improve service efficiency, and provide a more personalized experience. You can disable cookies through your device or browser settings, but this may affect the normal use of some App functions.
2.3 Personal Data Collected from Third Parties
If you choose to log in to the App through a third-party account (such as social media accounts), we may collect limited personal data (such as nickname, avatar) from the relevant third party with your explicit consent. The collection and use of such data will comply with the relevant agreements between us and the third party, as well as the PDPA.
3. Purpose of Using Your Personal Data
We only use your personal data for the purposes specified in this Policy, and will not use it for any other purposes without your explicit consent. The specific purposes are as follows:
- To Provide and Maintain App Services: Create and manage your account, verify your identity, provide novel and comic drama content, process payment transactions, and ensure the stable and secure operation of the App.
- To Personalize Your Service Experience: Analyze your usage habits and content preferences, provide personalized content recommendations, customize App interface settings, and improve your satisfaction with the services.
- To Communicate with You: Send you important information about your account (such as account registration confirmation, password reset notice), App updates, service announcements, and promotional information (with your consent). Respond to your inquiries, feedback, and complaints in a timely manner.
- To Ensure Security and Comply with Laws: Detect and prevent fraudulent activities, unauthorized access, and other illegal behaviors to protect the security of your account and personal data, as well as our legitimate rights and interests. Comply with legal obligations, court orders, subpoenas, and regulatory requirements of relevant authorities.
- To Improve Our Services: Analyze user behavior and usage data, identify problems and defects in the App, optimize content quality and service functions, and develop new services that meet user needs.
- To Conduct Marketing Activities: With your explicit consent, send you promotional information about our services, partner services, and related products. Conduct market research and analysis to improve marketing efficiency and effect.
4. Sharing and Disclosure of Personal Data
We attach great importance to the protection of your personal data and will not sell, rent, lease, or otherwise disclose your personal data to any third party without your explicit consent, except in the following circumstances:
4.1 With Your Explicit Consent
We may share your personal data with third parties when you have given us explicit written or oral consent. For example, if you agree to share your content preferences with a third-party content provider to obtain more accurate recommendations, we will share the relevant data in accordance with your consent.
4.2 With Third-Party Service Providers
We may share your personal data with third-party service providers who assist us in providing App services. These third-party service providers include but are not limited to technical support providers, payment processors, cloud storage service providers, and content distribution platforms. We will sign a strict confidentiality agreement with these third parties, requiring them to comply with the PDPA and relevant laws, and to use your personal data only for the purposes specified by us. We will also supervise and manage these third parties to ensure the security of your personal data.
4.3 For Legal and Regulatory Purposes
We may disclose your personal data if required to do so by law, regulation, court order, or subpoena. We may also disclose your personal data to protect our legitimate rights and interests, the safety of our users, or the public interest, such as in the case of detecting and preventing fraud, handling disputes, or responding to emergency situations that threaten the life, health, or safety of an individual.
4.4 In the Event of Business Transfers
In the event of a merger, acquisition, reorganization, sale of all or part of our assets, or other business transfer, your personal data may be transferred as part of the business assets. We will notify you of such a transfer in advance (via email, App notification, or other prominent means) and ensure that the acquirer or transferee complies with this Policy and the PDPA, and continues to protect your personal data.
4.5 Anonymized or Aggregated Data
We may anonymize or aggregate your personal data (so that it can no longer identify any individual) and share it with third parties for research, analysis, or marketing purposes. Such anonymized or aggregated data does not constitute personal data under the PDPA, and its sharing will not violate your privacy rights.
5. Data Retention
We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. The retention period is determined based on the following principles:
- For personal data used to provide App services (such as account information, usage records), we will retain it for the duration of your use of the App, and for a reasonable period after you terminate your account (to handle potential disputes, comply with legal obligations, or resolve after-sales issues).
- For personal data collected for specific purposes (such as promotional activities), we will retain it only for the duration of the specific purpose, and delete or anonymize it immediately after the purpose is achieved.
- If you request the deletion of your personal data or the termination of your account, we will delete or anonymize your personal data in a timely manner, unless we are required to retain it by law.
- When your personal data is no longer needed, we will adopt secure deletion methods (such as overwriting, physical destruction) to ensure that the data cannot be recovered or accessed.
6. Data Security
We take reasonable and appropriate security measures to protect your personal data from unauthorized access, collection, use, disclosure, modification, deletion, or damage, in accordance with the requirements of the PDPA. The specific security measures include:
Technical Security Measures
- Encrypt personal data in transit (using SSL/TLS encryption) and at rest (using encryption algorithms such as AES).
- Deploy firewalls, intrusion detection systems, and other technical tools to prevent network attacks and data breaches.
- Regularly update the App and server systems to fix security vulnerabilities.
Management Security Measures
- Establish a strict data security management system, clarify the responsibilities and authorities of relevant personnel, and restrict access to personal data (only authorized personnel can access the data).
- Conduct regular data security training for employees to enhance their awareness of data protection and compliance.
Emergency Response Measures
- Formulate a data breach emergency response plan.
- In the event of a data breach, we will immediately take measures to control the risk, notify the affected users and the Personal Data Protection Commission (PDPC) in accordance with legal requirements, and take remedial measures to reduce the impact on users.
Please note that no electronic storage or data transmission method is completely secure. We will do our best to protect your personal data, but we cannot guarantee absolute security. You should also take appropriate measures to protect your account and personal data (such as setting a strong password, not sharing your account information with others).
7. International Data Transfers
Your personal data may be transferred to and stored in countries or regions outside of Singapore (including but not limited to countries in Asia, Europe, and North America) for the purpose of providing App services (such as cloud storage, technical support). We strictly comply with the requirements of the PDPA for international data transfers, and take the following measures to ensure the protection of your personal data:
- Before transferring personal data overseas, we will take appropriate steps to confirm that the recipient of the data is bound by legally enforceable obligations to provide a level of protection comparable to that under the PDPA.
- We will sign standard contractual clauses (SCCs) with overseas recipients, which are recognized by the PDPC as a valid safeguard for international data transfers.
- We will obtain your explicit consent before transferring your personal data overseas (except in cases where the transfer is required by law or necessary to fulfill a contract with you).
8. Your Rights Under the PDPA
In accordance with the PDPA, you have the following rights regarding your personal data held by us. You can exercise these rights by contacting our DPO or customer service (contact information is provided in Section 9):
8.1 Right to Access
You have the right to request access to your personal data held by us, including the type, scope, and use of the data. We will provide you with a copy of your personal data within a reasonable time after receiving your valid request, and explain how we have used or disclosed the data.
8.2 Right to Correction
If you find that the personal data we hold about you is inaccurate or incomplete, you have the right to request us to correct it. We will verify the relevant information and correct the data in a timely manner, or inform you of the reasons for not being able to correct it.
8.3 Right to Withdraw Consent
You have the right to withdraw your consent to the collection, use, or disclosure of your personal data at any time. Withdrawing consent will not affect the legality of the processing of your personal data based on your consent before the withdrawal. After you withdraw consent, we will no longer collect, use, or disclose your personal data for the relevant purposes, unless required by law.
8.4 Right to Deletion
You have the right to request us to delete your personal data if it is no longer necessary for the purposes for which it was collected, or if you have withdrawn your consent and there is no other legal basis for retaining the data. We will delete or anonymize your personal data in a timely manner after receiving your valid request.
8.5 Right to Data Portability
You have the right to request us to provide your personal data in a machine-readable format, or to transfer it directly to another data controller (if technically feasible). We will fulfill your request within a reasonable time, subject to legal and technical constraints.
8.6 Right to Lodge a Complaint
If you believe that we have not complied with this Policy or the PDPA in the collection, use, or disclosure of your personal data, you can contact our DPO to lodge a complaint. If you are not satisfied with our handling of the complaint, you can also file a complaint with the Personal Data Protection Commission (PDPC) of Singapore.
9. Contact Us
If you have any questions, concerns, or requests regarding this Policy, the collection and use of your personal data, or the exercise of your rights under the PDPA, please contact us through the following channels:
We will respond to your inquiries and requests within a reasonable time (generally within 14 working days) and handle them in accordance with the PDPA and this Policy.
10. Changes to This Policy
We may update this Policy from time to time to adapt to changes in laws, regulations, technology, and our business practices. Any material changes to this Policy will be notified to you through prominent means (such as App pop-up notifications, email, or a notice on the App's homepage) at least 7 days before the changes take effect. The updated Policy will take effect on the effective date specified in the notice. By continuing to use the App after the changes take effect, you agree to the updated Policy. If you do not agree to the updated Policy, please cease using the App immediately.
11. Miscellaneous
This Policy is governed by the laws of Singapore. Any dispute arising from or in connection with this Policy shall be resolved through friendly negotiation between you and us. If the negotiation fails, either party may file a lawsuit with the courts of Singapore.
If any provision of this Policy is deemed invalid or unenforceable by a court of competent jurisdiction, the remaining provisions shall remain valid and enforceable.
This Policy constitutes the entire agreement between you and us regarding the collection, use, and protection of your personal data, and supersedes any prior oral or written agreements or understandings between you and us on the same subject matter.