隱私規定

Welcome to WebNovel! We understand the importance of your personal data and are committed to protecting your personal data’s security.

We are Cloudary Holdings Limited (hereinafter referred to as “WebNovel” or “We”). Our registered address is at Room 1503-04, ICBC Tower, 3 Garden Road, Central, Hong Kong. We operate digital reading and publishing platforms in different jurisdictions in accordance with applicable local laws and regulations. Such platforms include, but are not limited to, the WebNovel website (https://www.webnovel.com/) and WebNovel mobile application (hereinafter referred to as “WebNovel Platforms” or “our Services”). We are the data controller of personal data in connection with your use of WebNovel Services.

This Privacy Policy (hereinafter referred to as “this Policy”) describes how the WebNovel Platforms collect, use, disclose and otherwise process (collectively “process” or “processing”) your personal data. The applicable laws and regulations of certain jurisdictions may impose unique or different requirements on the processing and protection of personal data, and we will indicate the application of such requirements in the Appendix: Jurisdiction-specific Notices of this Policy.

1. How we collect and use your personal data
2. How we use cookies
3. How we share and disclose your personal data
4. International transfer of your personal data
5. How we protect your personal data
6. Your personal data rights
7. Information we may send to you
8. Protection of minors
9. Scope of Application
10. How we update this Policy
11. How to contact us

I. How We Collect and Use Your Personal Data

Personal data refers to any data that can directly or indirectly identify a specific natural person (“data subject”).

A. Source of Personal Data

When you use our services on the WebNovel Platforms, we will obtain your personal data (information underlined may be deemed as sensitive personal data in certain jurisdictions) in the following scenarios: information provided by you directly, information collected by us automatically, information from third parties, and publicly available information.

1. Information Provided by You Directly

When you use our Services, you might need to share some personal data with us so we can provide certain features.

• Profile Information: To create a WebNovel account, you need to give us your email address and login information (like your password or a verification code). You can also add extra details like your gender, profile photo, username, hometown and reading preference when you sign up or later.
• User-Generated Information: When you write comments about books or author a book on our platform, you share that contents with us. We also automatically collect and store information related to your account, the time of posting, and additional details associated with the content you post.
• Payment Information: When you top up your coins balance or purchase a membership, you need to provide us your payment card details, including your card number, security code (CVV), and expiration date. We also automatically collect and store information about your purchases, such as order numbers, transaction time, transaction amount, and purchased items.
• Communication Information: When you communicate with us (including through online feedback or customer service email), you need to provide us with the communication content information, including text, images, and audio/video information, as well as other communication information. In addition, we will automatically collect and store information about the communication, such as sending/receiving time, assigned customer service representative, and other related details.
• Event Information: When you participate in our research, study, marketing, competition or other events, you are required to provide us with the relevant information necessary for your participation.

If you provide the personal data of any individual (other than yourself) to us, you shall ensure that you have lawfully and duly informed the relevant data subject and obtained his/her consent (where required under applicable laws and regulations) to authorize us to process his/her personal data in accordance with this Policy.

2. Information Collected by us Automatically

When you use our Services, our platform may automatically collect and generate the personal data in connection with your use of our Services.

• Usage Information: We will automatically collect the information about your interaction with our Services, including records of your browsing, searching, bookmarking, sharing, downloading, commenting, writing and advertisement interactions (such as time, location (inferred from the IP address) and other descriptive attribute information), application usage (such as usage duration and frequency), and application performance data.
• Advertisement Information: We will automatically collect your advertisement identifiers (e.g., ADID, GAID, PPID, and IDFA), IP address, and records related to your interaction with advertisement on our platform, including details about the ads you view or engage with. Additionally, we may generate privacy protected identifiers such as Rampid or UID2 using your telephone number or email. These identifies help us display advertisements, including personalized advertisements, within our Services.
• Device Information: We will automatically collect the information related to your device, including:
• Device identifiers: device number, IMEI ID, device ID, ICCID, Android ID, IDFV, and advertisement identifiers (e.g., ADID, GAID, PPID, and IDFA);
• Network information: IP address, Mac address, Bluetooth address, and DHCP;
• Device parameter information (including hardware and software): device screen information, device brand and model information, system version, knobs, network information, network operator, resolution, date and time, time zone, country/region, language, network status, signal strength, disk/memory capacity, CPU information, device name, battery status and power, browser information (such as browser model, language, time zone, and screen height and width).
• Location Information: We will automatically collect your approximate geographical location information, mainly inferred from your IP address.
• Speculation Information: We may speculate on certain information about you, including your age range, preferences.
• Cookie Information: We use cookies and other similar technologies to manage and operate our Services, and automatically collect the cookie-related information. Please refer to our Cookie Policy for details.

Visitor User: In case you use our Services but don’t create an account, we still collect your usage information, advertisement information, device information, and location information.

3. Information from Third Parties

• Profile Information: When you log into WebNovel with a third-party platform account (such as Google, Facebook, Line and Twitter), we will get your profile information from those platforms, including your username, profile picture and email address, but only if you give us permission.
• Payment Information: When you top up your coins balance or purchase a membership, we will obtain your payment information and updates thereof from third-party payment service providers that we cooperate with (such as PayPal, Google Play Billing, and PaysafeCard), including transaction time, transaction amount, payment method, and serial number information.
• Statistical Analysis Information: We will obtain the attribution information (such as conversion rates of our advertisements displayed on third-party platforms) about advertisements for WebNovel, visit data, browsing and click-through data, as well as other information used for statistical analysis of our service situation, from our statistical analysis service providers or other partners.

4. Publicly available information

• Contents on Social Media Platforms: We will obtain the contents of public posts from social media platforms (such as Line, TikTok, Twitter, Facebook), such as your sharing, commenting, or liking of social media contents related to WebNovel, or your interactions generated on social media pages related to WebNovel.
• Information from Other Public Websites or Public Sources: To the extent permitted by applicable data protection laws, we may collect your publicly available personal data from other public websites or public sources.

B. Purposes for Collecting and Processing Personal data

We may collect and use your personal data for the following purposes. If you do not provide certain personal data to us, we may not be able to provide the relevant services to you. For the sake of reader-friendliness, this Section uses data categories instead of listing detailed data types. Please refer to Section I.A to find the specific data types associated with each data category.

1. To Register an Account

To become a registered user of the WebNovel Platforms, we will use the profile information provided by you to manage your account and provide you with a series of practical features.

2. To Provide Notification Services

We may collect and use your device information to provide you with message notifications through push notifications.

3. To Provide Content Publishing Services

When you use content publishing features on our platforms, we collect your user-generated information. When you use image upload features for posting content on our mobile applications, we request the camera permission and storage permission to enable photo capture/image uploading from your device’s local storage. These permissions are requested only when you actively use image-related features and are necessary to fulfill your photo capture and local image upload requirements.

When you share the content from WebNovel Platforms to a third-party social media platform, we may collect your profile information.

4. To Process Payments and Transactions

When you top up your coins balance or purchase a membership on WebNovel Platforms, we use your payment information to create and complete your orders, issue invoices, and ensure smooth transactions.

5. To Deliver Personalized Content and Recommendations

To provide personalized recommendations to you, including providing, analyzing, managing, improving, optimizing, selecting, and broadcasting books information, we will use your profile information, usage information, device information, location information and speculation information.

6. To Provide Customer Support

When you contact our customer support, we may use your profile information and communication information, which allows us to understand your needs and contact you as soon as possible.

7. To Ensure Security of Our Services

To provide the services to you in a secure manner and to help us better understand the operation of the application, we need to use your profile information, usage information, advertisement information, device information, location information and statistical analysis information.

8. To Conduct Statistical Analysis and Improve Our Services

We may use your profile information, usage information, device information, communication information, speculation information and statistical analysis information for research, analysis, and statistics, to continuously improve and optimize our Services. For example, we may conduct market research and trend analysis, comprehensively summarize and analyze the situation related to our Services, and develop products on this basis, so as to improve our platform and technology.

9. To Conduct Marketing and Promotion

We may use your profile information, usage information, advertisement information, device information, location information, and speculation information to send promotional messages about our Services and provide personalized advertisements to you.

10. Other Purposes

If we use your personal data for purposes not specified in this Policy or for new purposes different from those stated at the time of collection, we will obtain your consent for such use or rely on another legal basis for processing under applicable data protection laws.

C. Legal Basis for Processing Personal Data

• Applicable laws and regulations in different jurisdictions may provide for different legal basis for processing personal data. If the applicable laws and regulations in your jurisdiction mandates consent as the sole legal basis for processing personal data, then we request for your consent to our processing of your personal data in accordance with this Privacy Policy. The commonly used legal basis includes the following but may differ in your jurisdiction:
• Obtaining your consent: In case other legal basis cannot be applied, we will seek your consent.
• We rely on obtaining your consent for the following purpose: “Section I.B.5. To Deliver Personalized Content and Recommendations;” “Section I.B.9. To Conduct Marketing and Promotion.”
• Where the processing is necessary for the conclusion and performance of contract between you and us.
• We rely on the necessity for conclusion and performance of contract for the following purposes: “Section I.B.1. To Register an Account;” “Section I.B.2. To Provide Notification Services;” Section I.B.3. To Provide Content Publishing Services;” “Section I.B.4. To Process Payments and Transactions;” “Section I.B.5. To Deliver Personalized Content and Recommendations;” “Section 1.B.6. To Provide Customer Support.”
• Where necessary to pursue our (or a third party’s) legitimate interests which are not overridden by your interests or fundamental rights and freedoms;
• It is necessary for us to pursue our legitimate interests by achieving the following purposes: “Section I.B.5. To Deliver Personalized Content and Recommendations;” “Section I.B.7. To Ensure Security of Our Services;” “Section I.B.8. To Conduct Statistical Analysis and Improve Our Services;” “Section I.B.9. To Conduct Marketing and Promotion.”
• Where necessary to comply with our legal obligation;
• Where necessary to perform a task carried out in the public interest or in the exercise of official authority vested in us.

D. Retention Period and Deletion of Personal data

Please note that all personal data you provide when using our products or services will remain authorized for our use during your usage (except for information obtained under “I.B.7. To Ensure Security of Our Services,” which will be deleted six months after collection), unless you delete it or refuse our collection through system settings. We will delete or anonymize your personal data after we can no longer retain such information (e.g., the personal data is no longer necessary for the intended purposes), except if we are required to keep it by applicable laws, regulations or court orders.

If we decide to no longer provide our Services, we will stop collecting your personal data right away and notify you either individually or through announcements. We will also delete or anonymize any personal data about you, except if we are required to keep it by applicable laws, regulations or court orders.

II. How We Use Cookies

To ensure the proper functioning of our websites and offer you a user-friendly experience, we will store small data files named “cookie” on your mobile device. A cookie usually includes an identifier, the site name and some numbers and characters. You can manage or delete cookies according to your preference.

By using the cache clearing function available on the WebNovel Platforms, you will be able to remove all cookies stored on your device for our services. However, if you do so, you will need to re-enter the user settings each time you access WebNovel Platforms.

Please refer to our Cookie Policy for details.

III. How We Share and Disclose Your Personal Data

We will not sell your personal data. Under the following circumstances, we may share, entrust the processing of, transfer, or otherwise disclose your personal data to the necessary extent.

A. Sharing and Disclosure Within Our Corporate Group

We may share your personal data with our parent company, subsidiaries, and affiliates to provide and improve our services, conduct business operations, and ensure consistent service delivery across our platforms.

B. Sharing with Non-affiliated Third-Party Partners

1. Third-party Platform Partners

Some services provided by third-party platform partners may be integrated into our platform. When you use these services, such as registration/login of account, sharing contents and accessing the browser, we will share the device information and user-generated information with such third-party platform partners that is necessary to perform their services.

2. Payment Service Partners

When you purchase our membership benefits and use third-party payment services, we will share with the payment service providers your profile information, payment information and device information to process your order, complete your payment process, and ensure the security of the transaction.

3. Advertisement Partners

We may share your advertisement information, device information, location information, and speculation information to our advertisement partners (including advertisers, advertisement service providers, advertisement evaluation companies, and other partners) to provide personalized advertisements to you.

All third parties with whom we share personal data are contractually obligated to protect the confidentiality and security of your information and use it only for the specified purposes.

C. Entrusted Processing by Third Parties

We may entrust service providers to represent or assist us in providing services to you to support the development, operation, and improvement of WebNovel Platforms. The services provided by them will include IT and infrastructure services and notification services, customer service, marketing services, research, analysis and statistics, security risk control, and service optimization and improvement. The service providers will only act as data processor and will be entrusted to process the personal data required for provision of their services.

D. Sharing and Disclosure that is Necessary for Providing Our Services

To comply with laws, enforce or apply our Terms of Use and other agreements, respond to your rights, or protect the rights, property, or safety of WebNovel Platforms, you, and other WebNovel Platforms users—such as preventing fraud and illegal activities and reducing credit risk—we may exchange information with other companies and organizations. However, this does not include selling, renting, sharing, or otherwise disclosing personal data for commercial purposes in violation of the commitments made in this Policy.

We will only share or disclose your personal data that is necessary for providing our services and will require personal data recipients to take measures to protect the confidentiality and security of your personal data. We will obtain your separate explicit consent if we share your personal sensitive information or change the purpose for the processing and use of your personal data, if such consent is required under applicable laws and regulations.

E. Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity. We will notify you of any such transfer and ensure the receiving party commits to protecting your data in accordance with this Policy.

F. Aggregated and Anonymized Data

We may publicly disclose aggregated, anonymized information that cannot identify individual users, such as platform usage statistics, reading trends, and demographic insights, to understand how users interact with our products or services or to provide the public with insights into overall usage trends of our products or services.

We will not publicly disclose your personal data, unless we have obtained your explicit consent or satisfied another legal basis under applicable laws and regulations, or when you voluntarily choose to do so.

IV. International Transfer of Your Personal Data

Our Services are available globally, and we use service providers in multiple countries and regions. Your personal data is primarily stored on servers located in the United States. The data protection laws in the United States may differ from those in your jurisdiction. Where the transfer is not subject to an adequacy decision or regulations, we will take measures to comply with the legal requirements for cross-border transfer of personal data in applicable jurisdictions and strive to achieve materially equivalent level of data protection in your jurisdiction. If you have any questions or need more information, you can contact us by following the instructions in Section “XI. How to Contact Us” of this Policy.

V. How We Protect Your Personal Data

We strive to implement comprehensive industry-standard physical, electronic, and administrative security measures to safeguard your personal data. We actively establish data security management standards, and data security development guidelines to manage and regulate the storage and use of personal data, ensuring that we collect only information that is relevant to the services we provide.

We enforce comprehensive security controls on data by requiring confidentiality agreements from individuals who have access to personal data and through continuous monitoring and auditing mechanisms. These measures prevent your personal data from being accessed, disclosed, used, modified, damaged, or lost without authorization.

We make every effort to ensure the security of any information you transmit to us. However, please understand that due to technological limitations and various malicious methods that may exist in the internet environment, you should be aware that the systems and communication networks you use to access our services may encounter issues due to factors beyond our control.

VI. Your Personal Data

Under applicable data protection laws, you may enjoy all, or part of, the following rights to your personal data. The availability of these rights may vary depending on your jurisdiction and the legal basis for processing. You may request for exercising your rights by contacting us as indicated in “Section XI. How to Contact Us” of this Policy.

A. Know / Be Informed

You have the right to receive clear information about how we process your personal data, which we provide through this Policy.

B. Access Your Personal Data

You have the right to access your personal data, except as otherwise provided by applicable laws or regulations.

C. Correct or Supplement Your Personal Data

You can request correction of inaccurate personal data and completion of incomplete information.

D. Delete Your Personal Data

You are entitled to request that we erase your personal data, and we shall delete your personal data in accordance with circumstances specified under applicable laws and regulations. Please note that certain exceptions may be applicable where we may decline to comply with, or are legally obligated not to fulfill, your request, such as when necessary for establishing, exercising, or defending legal claims.

E. 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 (for example, for the defense of legal claims or for another’s protection).

F. Data Portability

You can receive a copy of your personal data in a structured, machine-readable format when processing is based on consent or contract and is carried out by automated means. You also have the right to request that we transfer that personal data to another party. To ensure the security of your personal data, we may need to verify your identity before processing your data portability request. Please note that direct transmission to another party can only be provided where it is technically feasible and does not adversely affect the rights and freedoms of others. While we strive to provide data portability services at no charge, in cases where fulfilling your request would require disproportionate effort or involve extraordinary costs due to the complexity or volume of data involved, we may need to charge a reasonable administrative fee, which we will discuss with you beforehand so you can decide how you would like to proceed.

G. Object

You are entitled to object to our processing of your personal data when such processing is grounded on our legitimate interests or public interests.

You may request that we refrain from using your personal data for marketing activities.

H. Object to Automated Individual Decision-making

We do not use automated decision-making and profiling to process any of your personal data.

I. Withdraw Your Consent

You are entitled to withdraw your consent at any point in time when our processing of personal data relies on your consent as the lawful basis. Following your withdrawal of consent, we may be unable to continue providing you with the relevant functions and services. Nevertheless, your decision to withdraw consent shall not impact our prior processing of personal data that was conducted based on your previously given consent.

J. Delete Your Account

You are entitled to delete your account of WebNovel Platforms through the following methods:

• WebNovel mobile application operation path: “Profile - Settings - Delete Accounts” or following the details provided in “Section XI. How to Contact Us” of this Policy
• WebNovel website operation path: following the details provided in “Section XI. How to Contact Us” of this Policy.

You can contact us to request deactivation of your account. After verifying your identity and clearing any assets in your account, we will provide you with the account deactivation service. Once your account is deactivated, we will cease providing you with our products or services and, upon your request, delete your personal data, except as otherwise required by law.

VII. Information We May Send to You

A. Service Communications

We may send you essential service-related communications, for example, account security notifications, service updates and maintenance notices, legal and policy changes, etc. These communications are necessary for our service provision and cannot be opted out of while maintaining an active account.

B. Emails and Push Notifications

When you use our products or services, we may send you emails or push notifications. You can choose to opt out of these communications through the operation path “Profile - Settings - Notifications” in the App or unsubscribe from email.

VIII. Protection of Minors

WebNovel is not directed toward individuals under 16 years of age (or the applicable age of majority in your jurisdiction), and we do not intentionally collect or solicit personal data from such users.

If you are a minor under applicable law, you must obtain prior consent from your parent or legal guardian before using our products or services. You should review this Policy under parental supervision and ensure you have received their consent before using our services or providing us with any information. If your parent or legal guardian does not approve of your use of our products or services in accordance with this Policy, you must immediately discontinue use and notify us promptly.

When we collect personal data from minors with proper parental or guardian consent, we will only use or disclose this information when permitted by law, explicitly authorized by the parent or guardian, or necessary to protect the minor’s welfare.

If you are a guardian of a minor, please carefully review this Policy before the minor registers for or uses our services. Should you have questions about the minor’s use of our products or services, or about the information they provide to us, please contact us immediately using the details provided in “Section XI. How to Contact Us” of this Policy.

We protect the confidentiality and security of minors’ information in accordance with applicable data protection laws and this Policy. If we discover that we have collected personal data from a minor without proper parental or guardian consent, we will delete such information promptly.

IX. Scope of Application

This Policy applies to all our products and services. Certain services may have specific privacy statements that provide additional details about information handling for those particular services. Where conflicts arise between this Policy and service-specific privacy statements, the service-specific statements take precedence. This Policy does not cover services offered by third-party companies or individuals.

X. How We Update This Policy

This Policy forms an integral part of the WebNovel User Service Agreement. We reserve the right to update or modify this Policy periodically. We will not diminish your rights under this Policy without your explicit consent.

We will notify you of any changes through appropriate means, including in-app notifications or pop-up messages, to ensure you are promptly informed of Privacy Policy modifications.

For material changes involving the purposes, methods, or categories of personal data processing, we will seek your renewed consent as required by applicable data protection laws.

XI. How to Contact Us

If you have any questions or concerns about this Policy, our data processing practices, or wish to exercise your privacy rights, you can contact us through the following methods:

Email: service@webnovel.com

Online Customer Service: Contact our customer service team through the online chat feature available under “CONTACTS” of the bottom of WebNovel website, or at “Profile - Online customer service” in the WebNovel mobile application.

Response Time: We aim to respond to privacy inquiries within 15 working days or as required by applicable law.

A. For Users in the European Economic Area (“EEA”) and the United Kingdom (“UK”)

1.Legal basis for collecting and processing personal data

For each processing purpose specified in Section I.B of this Policy, the legal bases we rely on are as follows:

2. Protection of Minors

In the EEA, you must be at least 16 years of age to use our services (or the applicable age of majority in your jurisdiction, no less than 13 years of age). In the UK, you must be at least 13 years of age to use our services. Otherwise, please make sure that your parent or another holder of parental responsibility also read this Policy, and give or authorize the consent to our processing of your personal data.

B. For Users in Japan

1. Cross-border transfer of personal data

Your personal data is primarily stored on servers located in the United States for the purposes of providing and improving our services. The data protection laws in the United States are different from Japan. You can learn about the personal data protection legal system in the United States through the following links:

• United States: https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_america/

To protect the security of your personal data, we have adopted multi-level protection measures in terms of technology, organization, management, etc. For details, please refer to Section V of this Policy.

2. Protection of minors

In Japan, you must be at least 16 years old to use our services. Otherwise, please make sure that your parent or another holder of parental responsibility also read this Policy, and give or authorize the consent to our processing of your personal data.

C. For Users in the United States (“US”)

1. Collection of Personal Data

Within the past 12 months, the categories of personal data we collect and the categories of source from which the personal data is collected are detailed in Section I.A of this Policy; the business or commercial purposes for collecting the personal data are detailed in Section I.B of this Policy. Depending on how and to what extent you use our services, the actual categories of personal data collected may vary (for example, if you do not top up your coins balance or purchase a membership, we will not collect your relevant payment information), as detailed in Section I of this Policy. You may also contact us using the contact information in Section XI of this Policy for additional information.

In certain states (such as California), the following personal data may constitute sensitive personal data: your geographic location, payment card information and transaction amount. In certain states (such as Virginia), processing your sensitive personal data requires obtaining your consent. However, we do not collect or process sensitive personal data as defined under Virginia's applicable data protection laws.

2. Disclosure of Personal Data (Including Sharing)

The categories of personal data we have shared or disclosed to third parties for business purposes within the past 12 months, the business or commercial purposes for sharing the personal data, and the categories of third parties to whom we disclose the personal data are detailed in Section I.B and Section III of this Policy. Depending on how and to what extent you use our services, the actual categories of personal data disclosed may vary (for example, if you do not use third-party payment services, we will not disclose your relevant payment information). You may also contact us using the contact information in Section XI of this Policy for additional information.

We do not “sell” your personal data in exchange for monetary or other valuable consideration, although we may indirectly benefit from disclosing your personal data to third parties. We also do not share the personal data of consumers if we have actual knowledge that you are less than 16 years of age, unless you, in the case that you are at least 13 years of age and less than 16 years of age, or your parent or guardian, in the case that you are less than 13 years of age, have/has affirmatively authorized the sharing of your personal data.

3. Legal Basis for Processing Your Personal Data

For US residents, we usually do not need a legal basis to process your personal data, except for certain circumstances that require your consent or opt-in.

4. Your Personal Data Rights

In addition to the types of rights listed in Section VI of this Policy, you have the following rights regarding your personal data, subject to the limitations of applicable state data protection laws.

• Limit our use and disclosure of your sensitive personal data: You have the right to limit our use and disclosure of your sensitive personal data to what is necessary to provide you with our services.
• Right to opt out: You have the right to request that we stop the following activities, and we will comply with your request unless you authorize us to continue such activities:
• Selling or sharing your personal data to third parties for cross-context advertising purposes;
• Cross-platform, personalized targeted advertising.
• No Retaliation Following Opt Out or Exercise of Other Rights: We will not discriminate against you because you exercise any of your rights.

Agent Requests: If you are a US resident who has the right to use an authorized agent, you may use an authorized agent to submit rights requests on your behalf. An authorized agent may submit requests to us on your behalf, accompanied by a statement demonstrating their authority to act on your behalf as required by us. Please note that verifying and fulfilling agent-submitted requests may require additional time. Once confirmed, your authorized agent may exercise rights on your behalf, subject to applicable laws and regulations.

Appeals: When we deny your rights request, if you are a US resident who has the right to appeal our rights decisions, you may appeal to us regarding our decisions concerning personal data rights requests. When submitting an appeal request, please use the same email address or other contact method you used for your initial rights request to help us connect your appeal with your initial rights request. Please also attach supporting documents or information regarding your appeal.

5. Protection of Minors

In the United States (unless specific states have special provisions), you must be at least 13 years of age to use our services. Otherwise, please make sure that your parent or another holder of parental responsibility also read this Policy, and give or authorize the consent to our processing of your personal data.