Last update: September 11, 2023
Welcome to Novel 360
We are committed to protecting and respecting your privacy. This policy applies to the Novel 360 apps, websites, and related services (the “Platform”). It explains our practices concerning the personal data we collect from you, or that you provide to us, in connection with the Platform. It does not apply to other products or services that display or reference a different privacy policy. If you do not agree with this policy, you should not use the Platform.
The Platform is provided and controlled by HONG KONG ZHI HUAXI NGTONG NETWORK Corporation TECHNOLOGY CO., LIMITED, if you have any questions about how we use your personal data, please contact liangyanni8@gmail.com.
Please note that Supplemental Terms – Jurisdiction-Specific at the end of this policy may apply to you depending on the jurisdiction from which you are accessing our services and using the platform, which are deemed to be incorporated into this policy by reference.
For the purposes of this policy, unless the context otherwise requires, “you” and “your” means you, the user of the Services, and “information” means information which we collect about you or which is provided to us by you, including your personal data.
The information we collect depends on how you use the Platform and the choices you make. We collect information about you from different sources and in various ways when you use our products, including information you provide directly, third-party data sources, information collected automatically, and data we infer or generate from other data. More information about the categories and sources of information is provided below.
Information you choose to provide
If you access or use the Platform as a registered user, we may collect your nickname, age, email address, password and profile photo. If you choose to use the Platform as a non-registered user, we may collect your age. For both registered and non-registered users, the age information is used for verifying whether you are a qualified user of Novel 360.
If you request to withdraw the balance from your account, we may collect payment information, such as PayPal or other third-party payment information (where required for the purpose of payment).
If you provide feedback or contact us, or otherwise provide information voluntarily to us, our employees, or our contractors, the data will be collected by us as well.
Information from Third Parties
You may choose to share certain data with us from third parties or through your use of the Platform, we may collect such third party data. We have set out further detail on the information we receive from third parties below:
Social Networks: If you connect a social network account to the Platform, we will collect information from the social network that it makes available, which may depend on your use and settings on the social network.
Business Partners: If you choose to register to use the Platform using your social network account details (e.g. Facebook, Twitter, Instagram, Google), you will provide us or allow your social network to provide us with your username and public profile. We will likewise share certain information with the relevant social network such as your app ID, access token and the referring URL.
Advertisers and Advertising Networks: We use the information collected from you, and your interaction with the Platform and other third party sites, to infer your likely interests to provide you with more relevant advertising.
Information we collect automatically
We automatically collect certain information from you when you use the Platform including when you are using the App without an account. Such information includes:
Identifiers and device information: We automatically log your IP address, mobile carrier, time zone settings, device identifiers including mobile advertising IDs, and the version of the app you are using. We will also collect information regarding the device you are using to access the Platform such as the model of your device, the device system, network type, device ID, your screen resolution and operating system.
Usage data: We automatically log your activity on the Platform, including the content you view on the Platform, how long you spent viewing such content, access times, the URL of the website from which you came to our site, and other details about your use of and actions on the Platform.
Customer support information: We may collect details of your interactions with our customer service, such as the date, time and reason for contacting us, transcripts of any chat conversations.
Where you log-in from multiple devices, we will be able to use your profile information to identify your activity across devices.
Information we create or generate:
We infer new information from other data we collect, including using automated means to generate information about your likely preferences or other characteristics (“inferences”). We infer your general geographic location (such as city, state, and country) based on your IP address, system region, Mobile Country Code, Mobile Network Code, and mobile carrier information.
We use cookies, mobile IDs, and other similar technologies (e.g. web beacons, Flash cookies, etc.) (“Cookies”) to operate the Platform, enable us to provide certain features and functionality, and enhance your experience using the Platform.
Cookies are small text files placed on your device to store information that can be recalled by the web server in the same domain that placed the cookie. The text in a cookie often consists of a string of numbers and letters that uniquely identifies your device, but it can contain other information as well.
Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website. When your browser opens a webpage that contains a web beacon, it automatically connects to the web server that hosts the image (typically hosted by a third-party). This allows that web server to log information about your device and to set and read its own cookies..
Mobile analytics and advertising IDs are generated by operating systems for mobile devices (iOS and Android) and can be accessed and used by apps in much the same way that websites access and use cookies. Our Platform contains software that enables our third-party analytics and advertising partners to access the mobile IDs. We, and our analytics and advertising partners, use Cookies for the following purposes:
Strictly necessary Cookies: These are Cookies that are required for the operation of the Platform.They include, for example, Cookies that enable you to log into secure areas of the Platform.
Analytical/performance Cookies: They allow us to recognize and count the number of visitors and to see how visitors move around the Platform when they are using it. This helps us to improve the way the Platform works, for example, by ensuring that users are finding what they are looking for easily. Note that we use third-party analytics tools, including Google Analytics, to perform these functions. For further information on how Google Analytics collects and processes information about you, please click here and information on how to opt out of Google Analytics is available here.
Functionality Cookies: These are used to recognize you when you return to the Platform. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting Cookies: These Cookies record your visit to the Platform, the pages you have visited and the links you have followed. We will use this information to make the Platform and the advertising displayed on it more relevant to your interests. We may also make this information available to third party advertising partners, which may combine this information with information about your online activities over time and across different websites or online services for this purpose. These partners may participate in organizations that provide simple ways to opt out of analytics and ad targeting, which you can access at:
United States:
NAI(http://optout.networkadvertising.org) and DAA (http://optout.aboutads.info/)
Canada: Digital Advertising Alliance of Canada (https://youradchoices.ca/) Europe:European Digital Advertising Alliance (http://www.youronlinechoices.com/)
Cookie controls: Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our website.If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated.
Mobile advertising ID controls: iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs.
Email web beacons: Most email clients have settings which allow you to prevent the automatic downloading of images, which will disable web beacons in the email messages you read.
Do Not Track: Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our websites do not currently respond to browser DNT signals.Instead, you can use the range of other tools to control data collection and use,including the cookie controls and advertising controls described above.
We use your information to provide the Platform to you and to improve and administer it.
We generally use each of the categories of information we collect for the following purposes:
to provide the platform services
to improve and develop our platform and conduct product development
to measure and understand the effectiveness of the advertising we serve to you and others and to deliver targeted advertising
to use User Content as part of our advertising and marketing campaigns to promote the platform
to understand how you use the platform, including across your devices
to infer additional information about you, such as your age, gender, and interests
to help us detect abuse, fraud, and illegal activity on the platform
to ensure that you are old enough to use the platform (as required by law)
to provide customer support and respond to your questions
to communicate with you, including to notify you about changes in our services
to enforce our terms, conditions, and policies, and to meet our legal obligations
consistent with your permissions, to provide you with location-based services, such as advertising and other personalized content
to inform our algorithms
to combine all the information we collect or receive about you for any of the foregoing purposes
for any other purposes disclosed to you at the time we collect your information or pursuant to your consent.
We may share your personal data with selected third parties in or outside your country, including:
Our business partners so that we can make you special offers via the Platform;
Service providers or agents that provide services to us for any of the purposes described in this policy, such as cloud storage providers to store the information we collect and for disaster recovery services, as well as for the performance of any contract we entered into with you;
Analytics and advertising providers to help us in the optimisation and improvement of the Platform and to help us serve targeted adverts, as further described in the Cookies section of this policy.
We may also share your information with any members, subsidiaries, or affiliates of our corporate group, to provide the Platform including improving and optimising the Platform, preventing illegal use and supporting users.
We may share your information with law enforcement agencies, public or tax authorities or other organizations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
Comply with a legal obligation, process or request (including tax and related reporting requirements);
Enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;
Detect, prevent or otherwise address security, fraud or technical issues; or
Protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).
We will also disclose your information to third parties:
In the event that we sell or buy any business or assets (whether a result of liquidation, bankruptcy or otherwise), in which case we will disclose your data to the prospective seller or buyer of such business or assets; or
If we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.
Finally,we may share de-identified information in accordance with applicable law.
Please note that the Platform may include references or links to products provided by third parties whose privacy practices differ from ours. If you provide personal data to any of those third parties, or consent to our sharing personal data with them, that data is governed by their privacy policies.
The information that we collect from you may be transferred to, and stored at, a destination outside of your country. It may also be processed by staff operating outside your country who work for us, for one of our suppliers or one of our business partners. By submitting your information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this policy and applicable law.
Location of Processing European Personal Data: We transfer personal data from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections. To learn more about the European Commission’s decisions on the adequacy of personal data protections,please visit: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en
You can access and edit most of your profile information by signing into your account. We also provide a number of tools in Settings that allow you to control your information. Should you choose to do so, you may delete your entire account in Settings.
See the cookies section of this policy for choices about cookies and other analytics and advertising controls.
If you have any questions on how to use those tools, or want to know about any rights you may have in the country where you live,please contact us at the email address provided at the bottom of this policy.
EUROPEAN DATA PROTECTION RIGHTS
If the processing of personal data about you is subject to European Union data protection law, you have certain rights with respect to that data:
You can request access to, and rectification or erasure of, personal data;
If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format;
If the processing of personal data is based on your consent, you can withdraw consent at any time for future processing;
You can to object to, or obtain a restriction of, the processing of personal data under certain circumstances;and
For residents of France, you can send us specific instructions regarding the use of your data after your death.
To make such requests, contact us at the email address provided at the bottom of this policy. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.
We rely on different lawful bases for collecting and processing personal data about you, for example, with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.
CALIFORNIA PRIVACY RIGHTS
If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (“CCPA”), you have certain rights with respect to that information.
You have a right to request that we disclose to you the personal information we have collected about you and to receive additional information about our collection, use,disclosure, or sale of such personal information. You also have a right to request that we delete personal information under certain circumstances, subject to a number of exceptions. To make such requests, please contact us at the email address provided at the bottom of this policy.
Further, to provide or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. If you have an account, we will verify your request by asking you to send it from the email address associated with your account or to provide information necessary to verify your account.
Note that we do not “sell” personal information as defined by the CCPA.
You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
Finally, you have a right to not be discriminated against for exercising these rights set out in the CCPA.
We take reasonable and appropriate technical and organizational measures to help protect personal data from unauthorized access, use, disclosure, alteration, and destruction. Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your information transmitted via the Platform; any transmission is at your own risk.To help us protect personal data, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts.
We retain your information for as long as it is necessary to provide you with the service or fulfill the transactions you have requested or authorized. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data, including to comply with our legal obligations, enforce our agreements, resolve disputes, and as necessary for the establishment, exercise or defence of legal claims.
After you have deleted your account, we may retain certain information in an aggregated and anonymize format.
This Platform is not directed at children under the age of 13 or equivalent minimum age in the relevant jurisdiction. If you believe that we have personal data about or collected from a child under the relevant age, please contact us at zhxtTech@gmail.com.
In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at zhxtTech@gmail.com and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority or follow the dispute resolution process provided in the Terms of Service.
We will generally notify all users of any material changes to this policy, through a notice provided via the Platform. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued access to or use of the Platform after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Platform.
Questions, comments and requests regarding this policy should be addressed to zhxtTech@gmail.com.
13.1 Indonesia: If you are accessing our Platform in Indonesia, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.
Consent to the Privacy Policy: By checking the box or continuing use our services or continuing accessing the Platform, you acknowledge that you have read and understood this policy and hereby consent to us collecting, using, processing, disclosing or transferring your personal data in accordance with this policy. If you do not agree with this policy, you should not access or use the Platform or our services.
Information Relating to Children: The Platform is not directed at or suitable for use by children under the age of 14. If you access our services or Platform and you are below 21 years of age, or are not married and are under guardianship, you represent and warrant that you have obtained consent from your parent(s) or legal guardian(s) unless you indicate otherwise. By consenting to this policy, your parent(s) or legal guardian(s) are agreeing to take responsibility for: (i) all your actions in connection with your access or use the Platform or our services; (ii) any fees or charges associated with your use of any of the Services (as applicable); (iii) your compliance with this policy; and (iv) ensuring that any of your participation in Services will not, in any event, result in any violation of applicable laws and regulations relating to child protections. If you do not have consent from your parent(s) or legal guardian(s)), and your parent(s) or guardian(s) is not willing to open the account under their name, you must cease accessing the Services. You are not allowed to use the Platform or register an account on the Platform. If we become aware that personal data has been collected from a person under 21 years of age, or is not married and is under guardianship without any consent from their parents or legal guardian, we will delete this information and terminate the person’s account. If you believe that we may have personal data about or collected from a child under the age of 21 years old, please contact us at zhxtTech@gmail.com.
Right to Erasure: You have the right to ask us to delete personal data we hold about you by contacting us at zhxtTech@gmail.com : where you believe the personal data we hold about you is being unlawfully processed by us; where you have withdrawn your consent for the processing of your personal data by us; where the processing of your personal data is not in accordance with the original purposes of processing the personal data; where the processing of your personal data has exceeded the prescribed retention period pursuant to the applicable laws and regulations in Indonesia; and/or where your personal data have been disclosed and such disclosure has made you to incur certain damages.
Data Retention: We retain your information for as long as it is necessary to serve the purpose(s) for which such information was collected, including to provide you with the Platform or our services. Where we do not need your information in order to provide the Platform or our services, we retain it only for so long as we have a legitimate business or legal purpose in keeping such information: However, there are occasions where we are likely to keep this data for period of 5 years (or longer, if required) in accordance with our legal obligations or where it is necessary for our legal obligations, for the enforcement of our agreements, the establishment, exercise or defense of legal claims.
Language: This policy has been prepared in the English language and Indonesian language. In the event of any inconsistency or different interpretation between the English text and Indonesian text, the English text shall prevail and the relevant Indonesian text shall be deemed to be automatically amended to conform with and to make the relevant Indonesian text consistent with the relevant English text. You acknowledge that you have read this policy and understands its content and that this policy has been agreed freely and without duress. You acknowledge that you fully understand the language and the content of this policy, and you agree that you will not use the provisions under Law of the Republic of Indonesia No. 24 of 2009 on Flag, Language, State Emblem and National Anthem, Presidential Regulation No. 63 of 2019 on Use of Indonesian Language or any other laws and regulations to invalidate this policy.
13.2 India: The platform is not directed at those under the age of majority (18 years). If we become aware that personal information has been collected from a minor we will delete this information and terminate the person’s account. If you believe that we have collected information from a minor, please contact us at zhxtTech@gmail.com.
Grievance Officer For India
In accordance with Information Technology Act 2000 and rules framed thereunder, a Grievance Officer has been appointed and a complaint or other issue faced by a user of Our platform or other issue faced may be submitted through email at the below address.
The complaint should provide: (i) username of the relevant account holder (ii) specific content that is of concern and (iii) reason(s) for the request.
In accordance with Information Technology Act 2000 and rules framed there under, the contact details of the Grievance Officer are provided below:
Email: zhxtTech@gmail.com
13.3 South Africa: If you are accessing our Platform in South Africa, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.
Consent to the Privacy Policy: By checking the box or continuing to use our services or continuing to access the platform, you acknowledge that you have read and understood this policy and hereby consent to us collecting, using, processing, disclosing or transferring your personal data/information in accordance with this policy. If you do not agree with this policy, you should not access or use the Platform or our services.
Information Relating to Children: The Platform is not directed at or suitable for use by children under the age 12. If you access our services or Platform and you are below 18 years of age, or are not married and are under guardianship, you represent and warrant that you have obtained consent from your parent(s) or legal guardian(s) unless you indicate otherwise. By consenting to this policy, your parent(s) or legal guardian(s) are agreeing to take responsibility for: (i) all your actions in connection with your access or use of the Platform or our services; (ii) any fees or charges associated with your use of any of the Services (as applicable); (iii) your compliance with this policy; and (iv) ensuring that any of your participation in Services will not, in any event, result in any violation of applicable laws and regulations relating to child protections. If you do not have consent from your parent(s) or legal guardian(s)), and your parent(s) or guardian(s) is not willing to open the account under their name, you must cease accessing the Services and you are then not allowed to use the Platform or register an account on the Platform. If we become aware that personal data has been collected from a person under 18 years of age, or is not married and is under guardianship without any consent from their parent(s) or legal guardian(s), we will delete this information and terminate the relevant person's account. If you believe that we may have personal data about or collected from a child under the age of 18 years old, please contact us at zhxtTech@gmail.com.
Rights to Access, Erasure and Objection. You have the right (which rights may be exercised by contacting us at zhxtTech@gmail.com) to:
a. request whether we hold any of your personal data/information and to request access to your personal data/information (should we hold such data/information);
b. request us to correct, destroy or delete your personal data/information;
c. object, on reasonable grounds relating to your particular situation to the processing by us of your personal data/information;
d. to lodge a complaint with the Information Regulator regarding the processing of your personal data/information, but we encourage you to first contact us with any questions or concerns. The Information Regulator's contact details are:
Complaints email: zhxtTech@gmail.com .
Data Retention: We retain your information for as long as it is necessary to serve the purpose(s) for which such information was collected, including to provide you with the Platform or our services. Where we do not need your information in order to provide the Platform or our services, we retain it only for so long as we have a legitimate business or legal purpose in keeping such information. However, there are occasions where we are likely to keep this data for period of 5 years (or longer, if required) in accordance with our legal obligations or where it is necessary for our legal obligations, for the enforcement of our agreements, the establishment, exercise or defense of legal claims.
13.4 Brazil: If you are using the Platform in Brazil, the following additional terms apply. If any conflict arises between the main Privacy Policy and the additional terms, the following terms shall prevail:
Parental and Guardian Consent: If required by Brazilian data protection laws, (i) if you are over the age of 16 but under the age of 18, you can only use and register for an account with the assistance of your parent or legal guardian and you declare and represent that you had such assistance to use the Services and to agree to the Policy; (ii) if you are over the age of 13 but under the age of 16, you can only use and register for an account with the representation of your parent or legal guardian, and you must obtain the consent from your parent or legal guardian to the use of the Services and acceptance of this Privacy Policy.
Exercise of data protection rights: Brazilian law provides certain rights to individuals with regard to their personal data. Thus, we seek to ensure transparency and access controls in order to allow users to benefit from the mentioned rights.
We will respond and/or fulfill your requests for the exercise of your rights below, according to the applicable law and when applicable, to the Brazilian General Data Protection Law - LGPD:
I. confirmation of whether your data are being processed;
II. access to your data;
III. correction of incomplete, inaccurate or outdated data;
IV. anonymization, blocking or erasure of data;
V. portability of personal data to a third party;
VI. object to the processing of personal data;
VII. information of public and private entities with which we shared data;
VIII. information about the possibility to refuse providing personal data and the respective consequences, when applicable;
IX. withdrawal of your consent.
Verifying your identity: For your safety and to allow us to make sure that we do not disclose any of your personal data to unauthorized third parties, in order to verify your identity and guarantee the adequate exercise of your rights, we may request specific information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and finally responding to your request.
Limitations to your rights: In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when a disclosure could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulfill your request.
Contact: In case of doubt about your privacy, your rights or how to exercise them, please contact us through the form "Contact". If you have any questions about the processing of your personal data, we would like to clarify them.
If you wish to reach the Novel 360's Data Protection Officer, contact us at: zhxtTech@gmail.com.
Access Logs: We keep your application access logs under confidentiality, in a controlled and safe environment, for, at least, 6 months, in order to comply with legal obligations.
Language: The Policy may have been prepared in the English language and in the Portuguese language. If you are a user located in Brazil, you shall refer to the Portuguese version, which shall prevail.
13.5 Mexico: If you use our services in Mexico, the following additional terms apply. In the event of a conflict between the following additional terms and the provisions of the main body, the following terms shall take precedent.
How we use your personal data:
Almost all the processing purposes included in the main body of the Privacy Policy are necessary. However, the following are secondary purposes:
improve and develop our Platform and carry out product development
measure and understand the effectiveness of the advertising we deliver, and to deliver targeted advertising
use User Content as part of our advertising and marketing campaigns to promote the Platform, Provide you with personalized advertising
in accordance with your permissions, offer you location-based services, such as advertising and other personalized content.
The above purposes are not necessary to provide the Platform service, but allow us to provide you with a better experience. We offer you the ability to make choices about how we use and disclose your personal data. You can always limit the secondary purposes of by using the Settings that allow you to limit certain features. You can also contact us at zhxtTech@gmail.com to limit the processing according to your preferences.
We use both human and automated means to process your data.
By providing us with your personal data and using our Platform, you agree to transfers that require your consent. You can always revoke your consent and exercise your rights, as indicated below.
Your rights:
You have the following rights regarding your personal data: access, rectification, cancellation, opposition, cosent opt-out, and limitation of the use and disclosure of your data. You can exercise your rights by sending your request to zhxtTech@gmail.com. To know the applicable requirements and the procedure to exercise your rights, please contact us at the aforementioned email address. If you are under the age of 18, you may exercise your rights through a parent or guardian. Requests for your rights will be resolved as soon as possible according to the nature of your request.