Dear users: FishNovel (hereinafter referred to as "FishNovel") is operated and served by HONG KONG ELEPHANT NETWORK TECHNOLOGY CO., LIMITED (hereinafter referred to as "HK ELEPHANT") and its affiliates. HK ELEPHANT respects your personal information and data, and will do its best to protect your personal information and data safety and reliability. This policy applies only to user information and data collected and stored by FishNovel. Please read, understand and agree to the Privacy Policy of FishNovel carefully before using FishNovel. This policy sets out how we will collect, use, disclose, process and protect the information you provide us when you use FishNovell fiction. If we require you to provide certain information to verify your identity when using the Products and to connect to our third party service providers, we will use such information in strict accordance with this Privacy Policy. If you have started using FishNovell Fiction, you have read, approved and accepted all of the terms described in this Privacy Policy and any changes we may make at any time in the future. In addition, you need to promise that you are an adult when you start using the Product or, if you are a minor, that your guardian agrees to your use of the Product and agrees to the relevant terms of service and privacy policy.

About us

1. FishNovel is operated and served by HONG KONG ELEPHANT NETWORK TECHNOLOGY CO., LIMITED and its affiliated companies.

2. Affiliated company refers to the company or organization that currently or in the future controls UnicOM International Information Technology Co., LTD., is controlled by UNICOM International Information Technology Co., LTD., or is under the common control of UnicOM International Information Technology Co., LTD. Control means the ability to directly or indirectly influence the management/operation of a controlled object through ownership, voting shares, contracts, actual operating affiliations or other means determined by law.

I. [User Personal Information Protection and Privacy Protection]

1.1 Protection of users' personal information is a basic principle of FishNovel. We are committed to improving the transparency of information processing, enhancing your information management convenience, and protecting your information and communication security. Strictly abide by laws and regulations, follow the following privacy protection principles, to provide you with more secure and reliable services:

(1) Safe and reliable: We do our best to prevent your information leakage, damage and loss through reasonable and effective information security technology and management process;

(2) Protection of communication secrets: We strictly comply with laws and regulations to protect your communication secrets and provide you with secure communication services;

(3) Reasonable and necessary: In order to provide you and other users with better services, we only collect necessary information;

(4) Clarity and transparency: We strive to introduce our privacy policy to you in a concise and easy-to-understand way so that you can clearly understand our information processing method;

(5) Privacy protection: We realize privacy protection technically in every link of product or service development by integrating various factors of law, product and design.

1.2 When you register an account or use the Service, you may need to fill in some necessary information (see Point 2, information we may collect). According to laws and regulations, you may need to fill in your real identity information. If your true information is incomplete, you may be restricted from using the Services. In general, we retain your personal information only for the shortest period necessary to achieve the purpose. When our products or services cease operations, we will notify you by notice or announcement, and delete or anonymize your personal information within a reasonable period of time;

1.3 Under normal circumstances, you may browse and modify the information you submit at any time. However, for security and identification reasons (such as number appeal service), you may not be able to modify the initial registration information and other verification information provided at the time of registration.

1.4 without your approval, FishNovels not to FishNovels fiction outside of any companies, organizations and individuals to disclose your personal information, guarantee not made public or disclosed to third parties or provide user registration information and users in the use of network service platform, server, or database is stored in the FishNovel non-public content and information, but except for the following situations:

(1) Obtain the explicit authorization of the user in advance;

(2) In accordance with relevant laws and regulations;

(3) in accordance with the requirements of relevant government departments and judicial organs;

(4) To safeguard social public interests.

1.5 If user information may be disclosed to a third party through other means due to user's use of third-party services or equipment, user shall understand the relevant terms of user information protection provided by the third party by himself, and FishNovell shall not bear the risks arising therefrom. These situations include: users using third-party applications on mobile devices; The user information collected by a third-party application may be sent to a third party for processing.

Ii. [Information we may collect]

According to the principle of legality, justice and necessity, we only collect the information necessary to realize the function of the product. We may collect, store and use the following information about you. Consent to this Agreement will be deemed as consent to us collecting your personal information and using it to the extent required by law and agreed herein.

2.1 We collect the following types of information:

2.1.1 Information required for Account Service:

(1) The information you fill in when registering your account: mobile phone number *, email address *;

(2) We may obtain information disclosed to us by a third party when you log in using the account of a third party partner, including user name and profile picture. For this part, please read the user agreement or privacy policy of the third-party partner service carefully.

(3) The information you fill in when editing the data: avatar, nickname;

(4) Personal account information display: avatar, nickname, in-app virtual currency balance *, recharge record *, consumption record *;

(5) Account security: We need to collect some of your information to ensure your account security and judge your account and transaction risks, including the following information: account login place *, login IP address *, login time, product version number, transaction information *, authentication information *; Once we detect the existence or suspected existence of account security risks, we will use relevant information to conduct security verification and risk elimination to ensure the security of the products and services we provide to you and protect your rights and interests.

2.1.2 Information required by products or services

(1) Text works and comics reading and listening functions: In order to better provide novel reading services for you, improve reading experience and optimize novel presentation effect, we need to collect the following information: Device model, device brand, UNIQUE IDENTIFIER (UUID), OPERATING system and application version, source channel, network type, login IP address, and log information * (operation logs, service logs, development logs, and blink rollback logs).

(2) Search function: When you use the search function, we need to collect your search terms and browsing records to provide you with better search results and improve our products and services;

(3) Personalized recommendation and push functions: In order to better recommend works for you, we may collect your personal information, including: Gender, reading preference * (category information of your favorite works that you actively fill in), reading record, browsing behavior, bookshelf behavior, transaction record *, device unique identifier * (IMEI, IMSI, ICCID, DEVICE MAC address, AndroidID, Android advertising ID), app startup and shutdown information, app list information, To collect and analyze information individually or in combination with other information in order to provide personalized services and push to you;

(4) Comments and q&A information release functions: When you use comments, dubbing, bullet screen and Posting functions, we will collect the graphic, audio and video information you voluntarily provide;

(5) Customer service/user feedback function: When you consult or appeal through customer service, we may need to collect your account information to verify your identity, and may also collect your mobile phone number * and email address filled in when you give feedback and suggestions;

(6) you join our activities in the submitted information: name, * *, shipping address, mobile phone number *. * Some of our services may require you to provide certain sensitive personal information (marked * in this Privacy Policy) to implement certain functions. If you choose not to provide this type of information, you may not be able to use certain functions of the service, but other functions of the service may not be affected. If you voluntarily provide your sensitive personal Information, it means that you agree that we will process your sensitive personal information in accordance with the purpose and manner described in this Policy;

* Personal sensitive information refers to personal information that, once disclosed, illegally provided or abused, may endanger personal and property safety, easily cause personal reputation, physical and mental health damage or discriminatory treatment. For example, sensitive personal information includes id number, personal biometric information, bank account number, communication content, health and physiological information, etc. The "Personal Information" or "Sensitive Personal Information" in this Privacy Policy is contained in the Personal Information Security Code of GB/T35273, and the definition is consistent with the definition in the Personal Information Security Code.

2.2 Based on user behavior and product characteristics, FishNovel may access the following contents on users' mobile phones:

2.2.1 For android users, for the purpose of providing, processing, maintaining, improving and developing our products and/or providing services to you when you use the relevant products provided by us, the products may obtain the following permissions on your terminal devices:

(1) When users download books, they need to store the book data into the SD card and write/delete the internal storage;

(2) When users read downloaded books, they read the internal storage because they need to read the book data;

(3) In order to confirm the storage mode of downloaded book data, it is necessary to determine whether the user inserts SD card and uses the permission of mounting file system;

(4) To calculate the free area of storage space and use the permission to obtain the application size;

(5) Users can choose to use the camera to take photos and videos and access the flash when uploading their profile pictures;

(6) Use the network access permission to use the networking function of the software;

(7) To judge the current network state of the user so as to prompt the user to obtain the network state of the user;

(8) Prompt the user to open the network and use the permission to change the network state;

(9) When the user downloads books, when the user's current network is 2G/3G/4G, the user is prompted to open the wifi network and use the permission to obtain or change the wifi state in order to save the user's traffic;

(10) Users can change the vertical and horizontal screen direction when reading and apply for permission to change system Settings;

(11) Read and write system Settings for users to adjust the brightness of mobile phones;

(12) In order to ensure that users can get the notification in the first time and ensure that the listening function can be used normally, the program is allowed to start up automatically and the background process is still allowed to run after the phone screen is closed;

(13) When the user is on the reading interface for setting, the user needs to use the permission to keep the screen on, so that the system will not close the screen because the user does not operate for a long time;

(14) In order to allow the application to flash back clear process restart, need to kill the background process function;

(15) The path of outgoing calls needs to be reset to support the live broadcast function.

2.2.2 For iOS users, when you use the Software, for the purpose of providing, processing, maintaining, improving and developing our products and/or providing services to you, the software may obtain the following permissions on your terminal devices:

(1) Access to the microphone for the purpose of obtaining the user's voice when using the playback function or dubbing function;

(2) In order to realize the function of uploading profile picture and Posting, users may need to use the camera permission of mobile phone;

(3) To allow users to save pictures, they may need to use album permission;

(4) In order to realize the normal operation of the software, network permission is required.

(5) In order to obtain the system advertising logo for more accurate recommendation, it may be necessary to use the permission to allow advertising tracking.

2.2.3 Permissions required for third-party SDK access Services

Our products and services may include products and services of third parties, as well as links to third party websites. Information about you may also be collected when you use these products or services. When third parties provide products and services to you, they may obtain the following permissions:

(1) When users download books, they need to store the book data into the SD card and write/delete the internal storage;

(2) When users read downloaded books, they read the internal storage because they need to read the book data;

(3) In order to confirm the storage mode of downloaded book data, it is necessary to determine whether the user inserts SD card and uses the permission of mounting file system;

(4) When using the voice reading function, the user needs to read the status and identity of the mobile phone to ensure that the voice reading function stops when an incoming call is made and the push service generates a unique identifier;

(5) Use the network access permission for the purpose of using the networking function of the software;

(6) To obtain the user's network state for judging the current network state of the user so as to prompt the user;

(7) Prompt the user to open the network and use the permission to change the network state;

(8) When the user downloads books, when the user's current network is 2G/3G/4G, the user is prompted to open the wifi network and use the permission to obtain or change the wifi state in order to save the user's traffic;

(9) Read and write system Settings for users to adjust the brightness of mobile phones;

(10) Use the permission to allow vibration in order to vibrate the mobile phone when sending the book update notification to the user;

(11) In order to monitor whether the function of sharing books with other applications is normal, the permitted program is used to obtain the current or recently running application permissions;

(12) When the user is in the setting reading interface is steady on, the user needs to use the permission to keep the screen steady on, so that the system will not close the screen because the user does not operate for a long time;

(13) Permission to obtain the installation package list: permission required for access to the UNIVERSAL SDK;

(14) To support push capability, access to additional location * provider commands is required;

(15) To use the third party basic picture loading library Glide, you need to obtain the rights to read and write contacts in the address book.

3. How we might use information

3.1 How might we use information

3.1.1 The User agrees that FishNovel needs to use the user's information resources for the following reasons:

(1) Provide you with core reading services;

(2) Security guarantee. We will use your information for identity verification, security prevention, anti-fraud monitoring, archive backup, customer security services;

(3) Product development and optimization. When our system fails, we will record and analyze the information generated when the system fails to optimize our services;

(4) Enable us to better understand how you access and use our services, so as to respond to your personalized needs, including personalized recommended books and personalized push;

(5) Software execution, software certification or software upgrade;

(6) To allow you to participate in surveys related to our products and services;

(7) To recommend advertisements, information and evaluations that may be of interest to you to further improve the effectiveness of our advertising and other promotional and promotional activities;

(8) With the consent of the users, the statistical data, behavior analysis and non-associated user identification information made based on the user information shall be provided to the cooperative units to show the cooperation effect;

(9) Service information provided for user push notification and FishNovel;

(10) Modify global system Settings; Change the screen display orientation; Testing using simulated site sources; Edit SMS or MMS messages.

3.1.2 Functions Related to the Use of personal Information:

(1) Personalized recommendation: Based on user device information and service log information, indirectly extract user preference feature *, and generate user crowd portrait, user display, push and possible commercial advertisement based on feature label;

(2) Basic account services: use your mobile phone number *, your intended nickname and password to create a starting account, and then use services that require platform accounts to be opened: comment, dubbing, Posting, sharing, check-in, activities, uploading/changing profile picture, and displaying public honors obtained by users;

(3) Social/publishing function: When you publish information in FishNovel, we need your personal information: nickname/avatar for public content publishing;

(4) When users participate in activities held in the site, we need users' personal information: nickname/avatar for display of lottery results, fan rankings and other public content.

3.2 In order to provide you with a better experience, improve our services or for other purposes you agree to, we may use the information collected through one of our services for our other services in accordance with relevant laws and regulations. Information collected when you use one of our services may be used in another service to provide you with specific content or to show you information relevant to you that is not universally pushed. You may also authorize us to use the information provided and stored by the Service for our other services if we provide the option in the relevant service.

3.3 To ensure the security of the Services and to help us better understand the operation of our applications, we may record relevant information, such as the frequency of your use of the applications, fault information, overall usage, performance data and the source of the applications. We do not combine the information we store in our analytics software with the personally identifiable information you provide in your application.

3.4 When you use our products or services, we may collect your information by placing secure cookies and related technologies, including your login information, browsing information and preference Settings. You can also set up a browser to manage cookies. However, please note that if cookies are disabled, you may not enjoy the best service experience and some services may not work properly. Cookies are very important to improve users' Internet use experience. We use cookies for the following purposes:

(1) Optimize login experience: Cookie can help you fill in your last login account name and simplify the steps of repeated operations by storing account information when you register and log in;

(2) Security: Cookies can help us ensure the security of data and services and check cheating, hacking and fraud against our products and services;

(3) Preference setting: used to save the user's simple personalized Settings.

3.5 Sharing and disclosure of information

3.5.1 We may share your personal information with third parties as required by laws and regulations, or with your express prior consent or manual selection;

3.5.2 For external processing purposes only, we may work with third party partners (third party service providers, contractors, agents, advertising partners, application developers, Representative or push notification we send E-mail communications service providers, to provide us with location * map service provider) service (they may not be located in your field to share your personal information, let them according to our instructions, privacy and security of privacy agreements and other relevant measures to process the information for us, If we share your information with the above third party, we will use encryption, anonymization and other means to protect your information security and use it for the following purposes:

(1) To provide you with our services;

(2) To achieve the purpose described in the section "How we use the information we collect";

(3) Perform our obligations and exercise our rights under the User Service Agreement;

(4) Understand, maintain and improve our services.

If we share your information with the above third party, we will use encryption and anonymization to protect your information security.

3.5.3 Prohibition and exception of information transfer

We will not transfer users' personal information with companies or organizations other than FishNovel providers, except in the following circumstances:

(1) Transfer with express consent: After obtaining your express consent, we will transfer your personal information to other parties;

(2) with the sustainable development of our business, when a merger, acquisition, assets transfer transactions lead to share your personal information to third parties, we will push notifications, announcements, inform you related situation, in accordance with the laws and regulations and not below the standard required by this agreement to protect or ask for new managers continue to protect your personal information.

3.5.4 We will use the collected information for big data analysis. We use the information collected to analyze and form industry insight reports that do not contain any personal information. We may disclose and share with our partners statistically processed information without identifying content for the purpose of understanding how users use our services or to let the public know the overall usage trend of our services.

3.5.5 We may disclose your personal Information for the following purposes:

(1) Comply with applicable laws and regulations and other relevant provisions;

(2) Abide by the provisions of court judgments, rulings or other legal procedures;

(3) Comply with the requirements of relevant government agencies or other legally authorized organizations;

(4) We have reason to believe that we need to comply with laws and regulations and other relevant provisions;

(5) To implement the relevant service agreement or this agreement and safeguard social and public interests.

3.5.6 Types involved in sharing, transferring and publicly disclosing personal information

(1) Types of personal information shared, transferred and publicly disclosed on the webpage: device number, network region, recharge/consumption amount *, reading books, commenting/thinking/dubbing/Posting, book rating, book list created, number of books read, author/user concerned, book collection/topic/book list;

(2) Types of personal information shared, transferred and publicly disclosed by the App: advertising service encryption provides the download of user device number, channel, version, platform, reading duration, book classification and payment amount through this channel *.

3.5.7 We are aware of the corresponding legal liabilities for sharing, transferring and publicly disclosing personal Information, and will take reasonable measures to ensure the security of personal information.

Iv. How do you access and control your personal Information?

4.1 You have control over your personal information in our products and/or services in a variety of ways, including: you can access, correct/modify, delete your personal Information, you can withdraw your consent to your personal information, and you can cancel your account. In order to facilitate you to exercise the above control, we provide you with operation guidelines and operation Settings on the relevant function page of the product. You can operate by yourself. If you have doubts or difficulties in the operation process, you can contact us at the end of the article for control, and we will deal with it for you in time.

4.1.1 Access to Your Personal Information

You may query or access your personal information in our products and/or services, including:

Account information: You can log in to your personal account, visit - "ME" - personal home page to access your personal information in your account, including: profile picture, nickname, community profile;

Use information: You can through the bookshelf page, search page, my page, at any time to consult your browsing history, bookshelf add records, search records, etc.;

Transaction consumption information * : You can view your transaction records * and consumption records * by visiting the "My Wallet" page - click on the account balance;

Other information: such as you during this visit or operation problems in the course of the aforementioned personal information cannot be obtained for other content, you can provide the way to contact us by the end of the article, we will verify your identity in within a reasonable time after you provide, but it is otherwise provided for in laws and regulations or except otherwise agreed by the policy.

4.1.2 Correct/modify your personal information

You may correct/modify your personal information in our products and/or services. To facilitate you to exercise your rights, we provide you with two ways to correct/modify online and to apply for correction/modification to us. For security and identification reasons such as number appeal services, you may not be able to modify the initial registration information and other verification information provided when registering.

For some of your personal information, we provide you with operation guidelines and Settings on the related function page of the product. You can directly correct/modify the operation guidelines as follows:

(1) "AVATAR/nickname/Community profile" information correction/modification interface: "ME" - personal homepage - Edit information;

(2) The interface for correcting/modifying the information of "Mobile number */ third-party account" is "ME" - Settings - Account and Security ";

4.1.3 Deletion and Deregistration

In general, we will only store your personal information for as long as required by laws and regulations or for as long as necessary. To facilitate you to exercise your right to delete, we provide you with two ways to delete yourself online and to apply to us for deletion.

For some of your personal information, we provide you with operation guidelines and Settings on the relevant function page of the product. You can delete it directly. Once you delete it, we will delete or anonymize such information unless otherwise stipulated by laws and regulations:

(1) The interface for deleting "Search history" information in the App is: Library/Illustration - Search - Search history;

(2) The interface for deleting "Reading Record" information in the App is "I" - Reading record;

Under the following circumstances, you may directly request us to delete your personal information, except that the data has been anonymized or otherwise stipulated by laws and regulations:

(1) If we deal with personal information in violation of laws and regulations;

(2) If we collect and use your personal information without obtaining your consent;

(3) If our processing of personal information violates our agreement with you;

(4) If you no longer use our products or services, or you cancel your account;

(5) If we no longer provide you with products or services.

We provide you with account cancellation permission. You can cancel your account through the functions in the App or contact our customer service. The operation interface is: "ME" - Settings - Account and Security - cancel account. Once you cancel your account, you will not be able to use the full line of user products we provide services and will automatically give up the existing rights and interests, so please exercise caution. Unless otherwise provided by laws and regulations, we will stop providing you with all our products and services after canceling our account. All content, information, data and records under our products and services that you have used through this account will be deleted or anonymized.

4.1.4 Withdrawal of consent

If you want to change the permission scope of related functions, you can change the permission scope of product management on your device. The operation page is System Settings - Application Details - Permission Settings/Notification Settings. When you cancel the authorization to collect relevant personal information, we will no longer collect such information, nor will we be able to provide you with the corresponding services mentioned above.

4.2 When you access, modify or delete relevant information, we may require you to verify your identity to protect the security of your account.

4.3 Please understand that due to technical limitations, legal or regulatory requirements, we may not be able to meet all your requirements, and we will respond to your requests within a reasonable period of time.

4.4 Personal Information Security protection measures and capabilities: It is a basic principle of FishNovel to protect users' personal information, and FishNovel will take reasonable measures to protect users' personal information. Unless otherwise stipulated by laws and regulations or this Agreement, FishNovell will not disclose or disclose user's personal information to any third party without user's permission. FishNovel adopts professional encryption storage and transmission for relevant information to ensure the security of users' personal information. FishNovell will use various security technologies and procedures to establish a sound management system to protect your personal information from unauthorized access, use or disclosure.

(1) In the aspect of data security transmission, cryptographic technology such as transport layer security protocol is adopted to prevent transmission link from being sniffed and intercepted by means of Https, and a secure privacy data collection environment is established to ensure the privacy and integrity of data collection;

(2) In terms of data security storage, classify and grade the data and take additional security protection measures such as independent and encrypted storage for users' sensitive personal information;

(3) In terms of data access and use security control, implement strict data access control mechanism, adopt multiple identity authentication technology, and monitor the behavior that can process your information to avoid illegal access and unauthorized use of data;

(4) Other measures to achieve data security protection.

4.5 in order to achieve the purpose of external processing, or only with continuous development of our business, when a merger, acquisition, assets transfer transactions, we may partner with a third party (third party service suppliers, contractors, agents, advertising partners, application developers) (they may not be located in your field to share your personal information, Allow them to process the information for us in accordance with our instructions, privacy Agreements, and other relevant confidentiality and security measures. If we share your information with the above third party, we will use encryption and anonymization to protect your information security.

Five, how do we deal with minors' personal information

We take the protection of children's personal information very seriously and our products, websites and services are mainly aimed at adults. Children should not create their own user accounts without the consent of a parent or guardian. Although local laws and customs define a child differently, we consider anyone under the age of 14 to be a child.

We will only store, use or publicly disclose child user information collected with the consent of a parent or guardian if it is permitted by law, with the express consent of the parent or guardian, or if it is necessary to protect the child, otherwise we will try to delete the data as soon as possible.

In view of the limitation of existing technology and business model, it is difficult for us to take the initiative to identify the personal information of children, if you find that we are unwittingly or without prior verifiable guardian permission to collect the children's personal information, you can contact us, we will try to delete after found, if we find the situation, We will also delete them in a timely manner, except where the law requires us to keep them.

6. How do you store your personal Information

(I) Location of information storage:

Personal information collected and generated by us during our operations in the People's Republic of China is stored in the People's Republic of China, except in the following circumstances:

1. Laws and regulations have clear provisions;

2. Obtain your explicit authorization;

3. You conduct cross-border transactions through the Internet and other personal initiatives.

In view of the above circumstances, we will ensure that your personal information is adequately protected in accordance with this Privacy Policy.

(II) Information storage time:

We will take reasonable and practicable measures to avoid collecting irrelevant personal information. We will only retain your personal information for as long as necessary to achieve the purpose stated in our cost policy, unless required by law. Our criteria for judging the aforementioned period include:

1. Complete the transaction objectives related to you, maintain the corresponding transaction and business records, and respond to your possible inquiries or complaints.

2. Ensure the safety and quality of the services we provide to you.

3. Do you agree with a longer retention period?

4. Whether there are other special provisions on the retention period.

After your personal information exceeds the retention period, we will delete or anonymize your personal information as required by applicable law.

Vii. [Agreement Update]

For the modified agreement, we will separately explain to you the purpose, scope and usage of the corresponding information by means of in-site letters, page prompts and red dots, and provide you with the means of voluntary consent, and collect and use your personal information after obtaining your express consent.

Company name: HONG KONG ELEPHANT NETWORK TECHNOLOGY CO., LIMITED

Registered address: RM18C, 27/F, Ho King Comm CTR, 2-16 Fayuen ST, Mongkok Kowloon, Hong Kong