Privacy Policy

We, ShunGuang Technology Limited ("we," "our," or "us"), operate the DramaFinds Platform ("Platform") and are the data controller responsible for processing your personal data. This Privacy Policy explains how we collect, use, store, share, and protect your personal data in compliance with international data protection standards, including the Hong Kong Personal Data (Privacy) Ordinance (PDPO), EU General Data Protection Regulation (GDPR), UK Data Protection Act (DPA), and California Consumer Privacy Act (CCPA).

By accessing or using the Platform, you acknowledge that you have read, understood, and agree to the practices described herein.

We collect personal data based on your interaction with the Platform (visitor, subscriber, or merchant partner):

2.1 Visitors (Unregistered Users)

• Technical and Security Data: IP address, access logs, browser type, operating system, device identifier.
• Cookie Data: Information collected via cookies and similar technologies (e.g., analytics cookies, functional cookies).

2.2 Subscribers (Registered End-Users)

• Identification and Contact Data: Full name, email address, phone number, billing address.
• Third-Party Login Data: Name and limited profile details from OAuth providers (Google, Apple, etc.) if you sign up via external services.
• Payment and Transaction Data: Billing details, subscription history, and payment method identifiers (handled by PCI-DSS compliant processors; we do not store full payment card numbers).
• Technical and Usage Data: Device information, browsing behavior, content access logs, and interaction with the Platform.
• Support Data: Communication logs, inquiry details, and support ticket records when you contact our team.

2.3 Merchant Partners (Business Accounts)

• KYC and Identification Data: Tax ID, company registration documents, passport/ID copy, proof of address.
• Financial Data: Bank account details (for commission payments, processed by licensed payment providers).
• Business Contact Data: Company name, contact person, email address, phone number, and physical address.

• Direct Collection: From you when you register an account, subscribe to services, make payments, or contact support.
• Automatic Collection: Via analytics tools, cookies, and server logs when you access or use the Platform.
• Third-Party Collection: From authorized third parties (payment processors, OAuth providers, fraud prevention services) to verify identity, process transactions, or enhance security.

We process your personal data for specific, lawful purposes with corresponding legal bases:

We do not sell your personal data to third parties. We may share your data only in the following circumstances:

• Service Providers: Licensed payment processors, hosting providers, CDN services, and fraud prevention tools (bound by confidentiality obligations and data protection laws).
• Legal Authorities: Public institutions or regulatory bodies if required by law, court order, or legal obligation.
• Merchant Partners: For end-users, limited transaction data with merchants whose content you access (subject to their privacy policies).
• Corporate Transactions: In the event of a merger, acquisition, or reorganization, with the acquiring entity (under equivalent privacy protections).

Your personal data may be transferred to and stored on servers outside your jurisdiction (e.g., Hong Kong, EU, U.S.). We ensure transfers comply with applicable laws:

• For countries deemed "adequate" by data protection authorities (e.g., EU adequacy list), no additional safeguards are required.
• For non-adequate countries, we use Standard Contractual Clauses (SCCs) or other approved mechanisms to ensure equivalent data protection.

We retain your personal data for:

• The duration of your contractual relationship, plus applicable statutory limitation periods (whichever is longer).
• The period necessary to fulfill legal obligations (e.g., tax, KYC, or security requirements).

Upon expiration of the retention period, we erase or irreversibly anonymize your data.

We implement reasonable security measures to protect your data from unauthorized access, disclosure, or modification:

• Encryption of data in transit (SSL/TLS) and at rest.
• Restricted access to personal data (limited to authorized personnel).
• Regular security audits, vulnerability assessments, and system monitoring.
• Compliance with industry standards (PCI-DSS for payment data, ISO 27001 for data security).

Despite these measures, no digital service is completely secure. You are responsible for protecting your account credentials.

Depending on your jurisdiction, you may exercise the following rights by contacting support@dramafinds.com:

• Right to be informed about data processing activities.
• Right to access your personal data and request a copy.
• Right to rectify inaccurate or incomplete data.
• Right to erasure ("right to be forgotten"), where legally permitted.
• Right to restrict or object to processing.
• Right to data portability (receive data in a machine-readable format).
• Right to withdraw consent (where processing is based on consent).
• Right to lodge a complaint with a data protection authority.

We will verify your identity before responding to requests and aim to provide a response within 14-30 business days (depending on the jurisdiction).

• Necessary Cookies: Required for Platform functionality (cannot be disabled).
• Functional Cookies: Enable personalized features (e.g., remembering login status) – you may disable these via browser settings.
• Analytics Cookies: Used to improve the Platform (e.g., tracking user behavior) – you may disable these via browser settings.

You can manage cookie preferences through your browser (e.g., Chrome, Safari, Firefox) or device settings. Disabling non-essential cookies may limit certain Platform functionalities.

We do not knowingly collect personal data from individuals under 13 years of age (COPPA compliance). If we discover we have collected data from a minor under 13, we will immediately delete the data and terminate the account. Parents or guardians may contact us to request data deletion.

We may update this Privacy Policy periodically. We will notify you of material changes via email or in-Platform notification at least 30 days in advance. The updated policy will be posted on the Platform with a revised "Last Updated" date. Continued use of the Platform after the effective date constitutes acceptance of the revised policy.

Personal Data is collected for the following purposes and using the following services:

13.1 Advertising

This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on this Website, possibly based on User interests. This does not mean that all personal data is used for this purpose. Information and conditions of use are shown below.

Some of the services listed below may use cookies to identify users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User's interests and behavior, including those detected outside this Website. For more information, please check the privacy policies of the relevant services.

In addition to any opt-out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.

Google AdSense (Google Ireland Limited)

Google AdSense is an advertising service provided by Google Ireland Limited. This service uses the "DoubleClick" Cookie, which tracks use of this Website and User behavior concerning ads, products and services offered. Users may decide to disable all the DoubleClick Cookies by clicking on: myadcenter.google.com.

• Personal Data processed: Cookies; Usage Data.
• Place of processing: Ireland – Privacy Policy – Opt Out.
• Category of personal information collected according to CCPA: internet information.

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in Section 9 (Your Data Subject Rights).

For users in the EEA, the UK and Switzerland, personalized advertising is only served on the basis of consent collected by Google's certified Consent Management Platform; see our Cookie Policy for how to change or withdraw that choice at any time.

13.2 Analytics

We use third-party information, reports, and analytics to understand the usage and browsing patterns of DramaFinds users. We also allow third-party analytics companies to include web beacons and cookies on DramaFinds. The information collected includes search terms, search parameters, user click rates, and other similar data. We use this information to improve DramaFinds and ensure that we deliver relevant content to our users.

Google Analytics (Google Ireland Limited)

Google Analytics is a web analysis service provided by Google Ireland Limited ("Google"). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

• Personal Data processed: Cookies; Usage Data.
• Place of processing: Ireland – Privacy Policy – Opt Out.
• Category of personal information collected according to CCPA: internet information.

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in Section 9 (Your Data Subject Rights).

Our own statistics service

We also operate our own statistics endpoint (stat.dramabc.com) that records page views and interaction events (page path, referrer, coarse device/browser information and a first-party visitor identifier stored on your device). It is used only to measure and improve the performance of the Platform, is not shared with advertising partners, and is not used for cross-site profiling.

13.3 Traffic optimization and distribution

We use third-party advertising companies to serve ads when you visit our Web site. These companies may use non-personal information (i.e., information that does not include your name, address, email address or telephone number) about your visits to this and other Web sites in an effort to provide advertisements about goods and services that may be of interest to you. To learn more about third-party advertising or to opt-out of such advertising, you can visit both the Network Advertising Initiative and the Digital Advertising Alliance.

For questions, requests, or complaints regarding this Privacy Policy or data processing:

• Company Name: ShunGuang Technology Limited
• Address: RM 701, UNIT 108, 7/F, TWR B, New Mandarin Plaza, 14 Science Museum Rd, Tsim Sha Tsui, Hong Kong
• Email: support@dramafinds.com