Privacy Policy

Last Updated: July 15, 2025

This Privacy Policy describes how CLOCKWISE INTERNATIONAL (HONG KONG) LIMITED ("we", "our", or "us"), the operator of the DramAct mobile application ("DramAct" or "App"), collects, uses, and discloses your information when you use our services. We are committed to protecting your privacy and handling your data in a transparent and lawful manner under the laws of the Hong Kong Special Administrative Region.

1. Introduction

By accessing or using DramAct, you agree to the terms of this Privacy Policy. If you do not agree, please do not use the App. This Privacy Policy is an integral part of our Terms of Use.

2. Eligibility

DramAct is intended for users aged 14 and above. Users under 18 must obtain consent from a legal guardian. We do not knowingly collect personal information from users under 14.

3. Underage User Privacy

DramAct is not intended for individuals under the age of 14, and we do not knowingly collect personal information from anyone under 14 years old.

If we become aware that we have inadvertently collected personal information from a user under the age of 14 without verified parental consent, we will take steps to delete such information as soon as possible.

If you believe we may have collected data from an underage user, please contact us at business@novellettes.com so we can promptly address the issue.

We encourage parents or legal guardians to supervise their children’s use of online services. If you are a parent or guardian and believe that your child has provided us with personal information without your consent, you may contact us to request removal.

We take child data protection seriously and implement reasonable technical measures (such as age gates, platform restrictions, and keyword filters) to help prevent unauthorized access by underage users.

4. Information We Collect

We collect the following types of information:

Account Information: When you register, we may collect your nickname, email address, and login credentials.

Device and Usage Information: We may collect data about your device (model, OS, IP address, time zone, language), app usage (screen views, clicks), and crash logs.

Subscription and Payment Info: We may collect transaction-related information via Apple Pay or Google Pay to process your subscription. We do not store full payment credentials.

Third-Party Login Info: If you log in using Google, Apple, or Facebook, we access your public profile (name and email) as authorized.

Payment information is processed by third-party app stores (e.g., Apple App Store, Google Play). We do not collect or store your full credit card or billing details.

5. How We Use Your Information

We use your information to:

Provide and operate DramAct and its features;

Authenticate users and secure accounts;

Process subscriptions and manage payment status;

Communicate service-related announcements and respond to support inquiries;

Analyze usage to improve performance and user experience;

Comply with legal obligations.

6. Sharing of Information

We do not sell your personal data. We may share information with:

Service Providers: Including Adjust and Firebase (for analytics and performance tracking), Apple Pay and Google Pay (for payment processing);

Third-Party Login Providers: When you authorize Google, Apple, or Facebook login;

Legal Authorities: Where required by law or legal process.

Each third-party provider has its own privacy policy. We ensure they implement appropriate safeguards.

7. Data Storage and International Transfers

Your data may be stored or processed on servers located outside your country or region. We ensure such transfers comply with applicable data protection laws.

By using DramAct, you consent to the transfer of your data to these jurisdictions.

8. Cookies and Tracking Technologies

We and our third-party partners (such as Firebase and Adjust) use cookies and similar tracking technologies to support essential features, monitor performance, and improve the App experience.

These tools help us understand general usage trends, such as which features are popular or where technical issues may occur. This allows us to enhance stability and functionality over time.

You can manage your cookie or tracking preferences by adjusting your device or operating system settings. Please note that disabling certain types of cookies may impact the availability or performance of some features.

9. Data Security

We implement reasonable safeguards to protect your information from unauthorized access or disclosure. However, no system can be completely secure.

10. Your Rights

You have the right to access, correct, or delete your personal data. You can manage your account settings within the App or contact us directly to make a request.

Depending on your location and applicable laws, you may also have the right to:

- Request the restriction of certain data processing activities;

- Object to specific types of data usage, such as for direct marketing (if applicable);

- Request a copy of your personal data in a portable format;

- Withdraw previously granted consent where applicable.

We will consider and respond to all requests in accordance with relevant laws. To make a privacy-related request, please contact us at business@novellettes.com.

11. Account Deletion

You may request to delete your account and associated data at any time by contacting us. Note that certain transactional or legal records may be retained as required.

We retain data only for as long as necessary to fulfill the purposes outlined in this policy, including legal, regulatory, or fraud prevention obligations.

The retention period may vary depending on the type of data and applicable laws in your jurisdiction.

12. Changes to This Policy

We may update this policy from time to time. Material changes will be notified via in-app message or email. Continued use of the App constitutes acceptance of the revised policy.

13. Contact Us

If you have any questions or concerns regarding this Privacy Policy, please contact us at:

Email: business@novellettes.com

Address: IFLAT/RM A 12/F ZJ 300, 300 LOCKHART ROAD, WAN CHAI HK