Privacy Policy

Welcome to the "Wah! Drama" application and related services (hereinafter referred to as the "Service"). "Wah! Drama" is operated by Sun Wah Media Group (Hong Kong) (hereinafter referred to as "we," "our company," or "Wah! Drama"). We fully understand the importance of your personal information and will do our utmost to protect the security and reliability of your personal information. We are committed to maintaining your trust in us and adhering to the following principles to protect your personal information: principle of consistency between rights and responsibilities, principle of clear purpose, principle of choice and consent, principle of data minimization, principle of ensuring security, principle of subject participation, principle of openness and transparency, etc.

This Privacy Policy (hereinafter referred to as the "Policy") will help you understand: what information we collect, why we collect this information, how we use this information, how we protect this information, and the rights you enjoy. Please read and fully understand the content of this Policy carefully, especially the clauses involving your significant rights and interests (such as clauses marked in bold or underlined). If you do not agree with any content of this Policy, please immediately stop using our Service.

We may collect the following types of information based on how you use the Service:

1.1 Account Registration Information

When you register and create a "Wah! Drama" account, we may collect the following information:

• Mobile phone number and email address you provide;
• Nickname, avatar, and password you set;
• Information you authorize us to obtain when logging in through third-party accounts (such as WeChat, Apple ID, Google account);
• Identity verification information you provide to complete account verification.

1.2 Device and Technical Information

When you use the Service, we automatically collect the following technical information:

• Device model, operating system version, unique device identifier, mobile network information, browser type;
• IP address, location, network operator information;
• Operation logs, access time, accessed pages, click records when you use the Service;
• Content information you upload or store through the Service.

1.3 Usage Behavior Information

We will collect behavior information generated during your use of the Service, including but not limited to:

• Video content you watch, viewing duration, viewing progress;
• Content you like, comment, share, or bookmark;
• Interactive activities you participate in, check-in records, friend invitation records;
• Keywords you search for, filter preferences, browsing habits.

1.4 Payment and Transaction Information

When you purchase our paid services or conduct virtual currency transactions, we will collect:

• Payment amount, payment time, payment method;
• Transaction order number, product or service information;
• Invoice information, delivery address (if applicable).

1.5 Location Information

With your explicit authorization, we may collect your location information to provide localized services, recommend nearby relevant content, or conduct regional data analysis.

We will follow the principles of lawfulness, fairness, and necessity, and use your personal information only for the following purposes:

2.1 Provide Core Services

• Create and maintain your account, provide account login and identity verification services;
• Provide personalized content recommendations based on your preferences;
• Provide video playback, resume playback, offline download and other functions;
• Process your orders and payment requests, provide membership services.

2.2 Improve Service Quality

• Analyze user behavior data to optimize product functions and user experience;
• Conduct product R&D, testing and upgrades, fix technical vulnerabilities;
• Statistics on service usage, conduct data analysis and business decisions.

2.3 Security Assurance and Risk Prevention

• Identity verification, security detection, fraud prevention;
• Detect, prevent, investigate, and handle illegal or non-compliant activities;
• Protect users or the public from personal or property safety infringements.

2.4 Marketing and Promotion Activities

• Send you product updates, activity notifications, and promotional information (you can choose to unsubscribe);
• Show you content or ads you may be interested in through personalized recommendations;
• Invite you to participate in user experience research, product testing, or satisfaction surveys.

2.5 Legal Compliance Requirements

• Comply with laws and regulations, cooperate with investigations by government regulatory agencies or judicial authorities;
• Protect our legitimate rights and interests, such as intellectual property rights, reputation rights, etc.;
• Fulfill our obligations under user agreements or privacy policies.

3.1 Sharing Principles

We promise not to share your personal information with third parties unless:

• We obtain your explicit consent;
• Required by laws and regulations or government authorities;
• Necessary to achieve the purposes described in this Policy;
• In the event of a merger, acquisition, or bankruptcy liquidation, if the transfer involves personal information, we will inform you of the recipient's information and require them to continue to be bound by this Policy.

3.2 Potential Sharing Parties

• Service Providers: Third-party service providers for payment processing, cloud storage, data analysis, customer service, technical support, etc.;
• Content Partners: Film and television content copyright holders, producers, and distributors;
• Marketing Partners: With your authorization, we may share necessary information with marketing partners to conduct joint promotion activities;
• Affiliated Companies: Our affiliated companies may access your information based on necessary purposes, but only to the extent necessary to fulfill their duties.

3.3 Public Disclosure

Except in the following situations, we will not publicly disclose your personal information:

• We obtain your explicit consent;
• Public disclosure based on legal provisions or reasonable grounds;
• In cases involving illegal activities that may endanger personal or property safety.

To ensure the normal operation of the Service, we will store small data files on your device. These files are called Cookies. Cookies typically contain identifiers, site names, and some numbers and characters.

4.1 Purpose of Cookies

• Remember your login status and maintain your session continuity;
• Record your preference settings (such as language selection, playback quality);
• Analyze website traffic and optimize product performance;
• Provide personalized content recommendations and ad delivery.

4.2 Your Management of Cookies

You can manage or delete Cookies through your browser settings. However, please note that disabling Cookies may affect some functions of the Service or cause functional abnormalities.

4.3 Web Beacons and Pixel Tags

We may use similar technologies such as Web Beacons or Pixel Tags to statistics email open rates, page visits, etc., helping us improve services and user experience.

In accordance with relevant laws and regulations, you enjoy the following rights regarding your personal information:

5.1 Right to Access

You have the right to access and review the personal information we hold about you.

5.2 Right to Rectification

If you find that your information is inaccurate or incomplete, you have the right to request us to correct or supplement it.

5.3 Right to Erasure

In the following circumstances, you can request us to delete your personal information:

• We violate laws and regulations or our agreement with you in collecting or using personal information;
• We violate laws and regulations or our agreement with you in sharing, transferring, or publicly disclosing your personal information;
• You no longer use our products or services, or you have cancelled your account;
• We have stopped providing products or services to you.

5.4 Right to Account Cancellation

You can apply to cancel your account through the "Cancel Account" function in the application or by contacting customer service. After the account is cancelled, we will stop using and delete your personal information, or anonymize it.

5.5 Right to Withdraw Consent

You can withdraw your previous authorization consent for us to collect and use personal information by changing device settings, turning off permissions, or adjusting preference settings in the application.

5.6 Right to Data Portability

You have the right to request us to transfer your personal information to you or a third party designated by you in a structured, machine-readable form.

5.7 How to Exercise Your Rights

To exercise the above rights, please contact us through the contact methods listed in Section 10 of this Policy. We will verify your identity and process your request within 15 working days.

We take reasonable technical measures and management systems to protect your personal information from unauthorized access, leakage, use, damage, or loss:

6.1 Technical Measures

• Adopt SSL/TLS encryption transmission technology;
• Encrypt storage of sensitive information;
• Adopt technical measures such as access control, permission management, and data desensitization;
• Deploy firewalls, intrusion detection systems, and security audit systems;
• Conduct regular security vulnerability scans and penetration testing.

6.2 Management Measures

• Establish data security management systems and operating procedures;
• Provide security awareness and privacy protection training for employees;
• Sign confidentiality agreements with employees who have access to personal information;
• Establish an emergency response mechanism for data security incidents.

6.3 Security Tips

Please note that no security measure can achieve absolute security. We recommend that you keep your account password properly, do not disclose your password to others, change your password regularly, and use the Service in a secure environment.

6.4 Data Retention Period

We will retain your personal information only for the period necessary to achieve the purposes described in this Policy, unless otherwise required by laws and regulations or agreed by you. When the retention period expires, we will delete your personal information or anonymize it.

We attach great importance to the protection of minors' personal information. If you are a minor under the age of 18, before using our Service, you should carefully read and agree to this Policy under the supervision and guidance of your parents or other guardians.

7.1 Restrictions on Collection of Minors' Information

We will not actively collect personal information from minors. If we discover that we have collected a minor's personal information without the guardian's consent, we will try to delete the relevant data as soon as possible.

7.2 Guardians' Rights

Parents or other guardians of minors have the right to review, correct, or delete the minor's personal information we collect, and have the right to refuse our further collection or use of such information.

7.3 Special Protection Measures

For minor users, we have taken the following special protection measures:

• Set up youth mode to limit usage time and access content;
• Disable recharge and reward functions for minor users;
• Establish a dedicated customer service channel for minors.

We reserve the right to revise this Privacy Policy from time to time based on business development, changes in laws and regulations, or technological advancements.

8.1 Revision Methods

The revised Policy will be notified to you through in-app notifications, pop-ups, emails, or other reasonable methods. If you continue to use our Service after the revision, it means that you have read, understood, and agreed to accept the revised Policy.

8.2 Significant Changes

If the revision involves your significant rights and interests (such as changes to the purpose, scope, or method of information collection), we will use more prominent methods to notify you and seek your consent.

8.3 Version Viewing

You can view the latest version of the Privacy Policy at any time through this page. We will mark the "Last Updated Date" and "Effective Date" at the top of the Policy.

Given that "Wah! Drama" is a service for global users, your personal information may be transferred to regions outside your country or region for processing, storage, or access.

9.1 Cross-Border Transfer Scenarios

• We have data centers in mainland China, Hong Kong, Southeast Asia, and other regions;
• Some of our service providers and partners may be located overseas;
• To achieve global services, data may flow between different countries or regions.

9.2 Protection Measures

We will ensure that cross-border transfers comply with relevant laws and regulations and take the following protection measures:

• Sign data protection agreements with overseas recipients;
• Conduct data protection impact assessments;
• Ensure overseas recipients have corresponding data protection capabilities;
• Adopt technical measures such as encryption and desensitization to ensure data security.

If you have any questions, comments, suggestions, or complaints about this Privacy Policy, or need to exercise your rights, please contact us through the following methods:

Customer Service Email: privacy@wahdrama.com

Online Customer Service: Contact through the "Help & Feedback" function in the application

Mailing Address: Hong Kong Special Administrative Region (specific address to be provided separately)

Contact Phone: +852-XXXX-XXXX (Weekdays 9:00-18:00)

We will verify your identity as soon as we receive your request and respond within 15 working days.

Complaints to Independent Regulatory Authorities:

If you are not satisfied with our handling result, you have the right to complain or file a lawsuit with relevant data protection regulatory authorities or consumer rights protection organizations.