Privacy Policy

Last Updated: January 10, 2025

This Privacy Policy outlines how we collect, use, and protect personal data or information ("Data") that we may gather from or about you. This policy applies to all individuals whose data may be collected and handled by XI CHEN INTERNATIONAL LIMITED, Ltd LIMITED (hereinafter collectively referred to as "XI CHEN INTERNATIONAL LIMITED, Ltd," "we," "us," or "our") as data controllers or processors. This Privacy Policy is an integral part of and governed by our User Terms of Service. Within this Privacy Policy ("Policy"), our products and services are referred to as "Services."

XI CHEN INTERNATIONAL LIMITED, Ltd is firmly committed to safeguarding the privacy of users of our products and services (hereafter known as "Users" or "You"). In the course of providing the Services, we may collect and utilize your personal information. The security of your personal data is of paramount importance to us. Thus, this policy is designed to elucidate how XI CHEN INTERNATIONAL LIMITED, Ltd, acting as a data controller, gathers and manages personal data (also known as "Personal Information") that you share or disclose to us. We may also function as a data processor when handling your personal data received or acquired from third parties.

We urge you to peruse this Policy (particularly the parts emphasized in bold or underlined) thoroughly prior to using the Services, so you can make an informed decision. Should you disagree with this Policy, kindly refrain from registering, logging in, accessing, or using the Services, and from sharing your personal data with us. If you prefer that we not utilize specific types of your personal data in line with this Privacy Policy, be aware that we might then be unable to offer you certain portions of our Services, you may lose access to and/or the ability to use particular features of our Services, and your overall customer experience could be impacted. By consenting to all the terms and conditions of this Policy, you are agreeing to our processing of your personal information in accordance with this Policy.

We are committed to processing your Data in accordance with the required standards. This includes protecting your privacy and ensuring the security of your Data in compliance with, in particular and where applicable, the requirements of The Hong Kong Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the “PDPO”), Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”), and The California Consumer Privacy Act of 2018 (the “CCPA”) where applicable.

1. Legal Basis for Using Your Data

Our primary objective in collecting your Data is to facilitate a more efficient and enjoyable experience for you and other users when utilizing our products and services. We strive to create a secure and engaging online environment for all users, and the collection of Data aids us in achieving this aim. While using the Services, we may gather and process details that could be directly or indirectly linked to your personal information. In either scenario, such details may be considered personal data under this Policy.

Information not directly tied to your personal identity: For instance, we may collect and process data about the user's source route, access sequence, and other information, such as tracking the source route and browser software of each user.

(Optional) Please be aware that if you share or post information in a public area visible to other users of the Services, and you reveal your personal information in response to information shared or posted by others, such information may be collected and utilized by others. If you discover that other users have improperly collected or used your or others' information, please contact us as directed in the "How to Contact Us" section.

2. Data We Collect

We may collect, use, and hold a range of different Data about you. For the purposes of carrying on our business (including preventing and addressing fraud, security or technical issues, the registration, activation, and management of your account with us, and the billing and charging of our products and services) and complying with laws, rules, guidelines, regulations, and/or requests issued by applicable government authorities, courts, law enforcement, or other authorities or regulatory bodies, you may be requested to provide Data such as, but not limited to:

• Contact details including account name, mobile number, email address;

• Data that you have shared with third-party social media platform operators (e.g., account login name, profile picture, contact details, language preference);

• Account details or Data relating to Services registered with us, including account name, account numbers and/or service numbers;

• Device-specific information such as hardware model, operating system, version, GAID (Google Advertising ID)/IDFA (Identifier For Advertising), setting configurations, and software and mobile network configuration;

• Information about how you use our Services, such as region information;

• All Data requested by applicable government authorities, courts, law enforcement, or other authorities or regulatory bodies to enable us to comply with or in connection with any law, rule, regulation, judgment, or court order (whether within or outside of Hong Kong).

Specifically, to better serve your needs and preferences, our web servers may collect Data relating to your website, device, or app activity. We may also collect aggregated, anonymous, statistical data on the server's usage so that we may better cater to the behavior of users of our Websites and mobile APPs. This type of Data may include, but is not limited to:

• Browser type, version, and user agent;

• Operating system;

• IP (Internet Protocol) address;

• Connection data, statistics on page views and/or referral URLs;

• Device ID, location (region);

• Videos watched or searched for;

• Links or images clicked on;

• Cookies and similar technologies and/or browser, app, or web server log data; and

• Device and software characteristics and/or configuration.

3. Methods of Data Collection

We will gather and obtain your information in the following manners:

• Information you provide directly, such as:

  • Information you supply when registering for a service account or using XI CHEN INTERNATIONAL LIMITED, Ltd;

  • Information you share with other users through the service and the information you save when using the service.

• Information we obtain about you, such as:

  • Log information, location information, and device information, which we collect, aggregate, and record when you use the Services.

• Information we obtain from third parties, such as:

  • Single sign-on platforms (Google, Apple, Facebook, etc.), related entities, business partners, or other customers, or your representatives with appropriate consent from you;

• Publicly available sources;

• Your visits on our websites, or mobile or TV apps (see “Privacy Data” section below); and/or

• Your participation in surveys or marketing promotions organized by us or on our behalf.

4. How We Use Your Data

We may collect, retain, and use your Data for purposes such as:

Assisting you with registration and login:

To provide you with our services, you need to supply basic registration or login information, such as Email address, mobile phone number, account name, language preference, and profile picture, to create an account.

You may also use a third-party platform account supported by us to log in to XI CHEN INTERNATIONAL LIMITED, Ltd; in this case, we will ask permissions to access relevant information (such as your account name, profile photo, Email address, phone number, language preference) from the third-party account as per your authorization.

Providing search services:

When utilizing the search function in XI CHEN INTERNATIONAL LIMITED, Ltd, we collect your search terms, browsing history, browsing duration, and interaction frequency. This information helps us deliver the content you need and services that may interest you more.

Offering top-up and inquiry services:

When you top up (purchase coins in XI CHEN INTERNATIONAL LIMITED, Ltd), we will collect details about your order and payment information. If you check the remaining coins in your user account, we will collect and display it on the relevant page. If you are using any third-party payment services to process your payment, you will provide your information (including payment account, email address, credit card/debit card information, etc.) directly to the third-party payment company; we do not collect and retain the above payment information except for transaction ID and payment amount, currency.

Providing online video on-demand and subscription services

Ensuring account security, service operation, and optimizing service experience

When using XI CHEN INTERNATIONAL LIMITED, Ltd, to help us detect account anomalies, understand product suitability, provide basic services (such as browsing, search), and maintain the smooth operation of basic functions, we may automatically collect, retain, and process information about your service usage and how you use it, including:

• Log details: When utilizing this service, we may automatically gather comprehensive information about your usage and save it as relevant network logs. These log details include your login account, search queries, IP Address, browser type, telecom provider, network environment, language, access date and time, and records such as total page views, push open records, time spent on the page, refresh records, post records, follow and subscribe records, favorites, and sharing.

• Device information: Based on the specific permissions you grant during the installation and use of XI CHEN INTERNATIONAL LIMITED, Ltd, we may receive and record information about your device (including device type, operating system and version, APP version, resolution, software package name, device settings, process and software list, GAID (Google Advertising ID)/IDFA (Identifier For Advertising), software and hardware feature information), as well as IP Address.

Providing information display and recommendation services:

We may use your information (such as interests, personalized tags, browsing and search history, device information, usage habits, location information, order information, etc.) and combine it to extract your browsing, search preferences, behavior patterns, and location information through recommendation algorithm modeling, programming, advertising models, user behavior analysis, and user profiling. This enables us to offer page displays and personalized content recommendations that better suit your needs.

Sending notifications to you:

We may send you service-related notices when necessary (e.g., when we suspend individual services due to system maintenance). If you wish to stop receiving messages from us, you can request that we cease sending them. However, we may continue to send messages in accordance with applicable laws and regulations.

Enhancing our services:

We may invite you to participate in service-related surveys to help us improve existing services or design new ones; simultaneously, we may use your information for software updates. Therefore, to maintain our legitimate interest in enhancing our services, we will process this personal data for this purpose.

Other uses of anonymous information:

You understand and agree that in certain cases, after collecting your information, we will de-identify and fully anonymize the Data through technical means, so it no longer constitutes personal data directly or indirectly related to you or others. The de-identified information does not identify or relate to you. In this case, we reserve the right to use such de-identified information for analysis and monetization of the user database.

If we intend to use your information for purposes not outlined in this Policy, we will seek your prior consent through page prompts, interactive processes, website announcements, or other means. Once you agree, such additional use of your information will be considered part of and subject to this Policy.

Notifications regarding permissions for specific features:

You acknowledge and agree that we may request certain access permissions on your device to gather and utilize information related to specific features and services. For instance:

• With your consent, we can access your storage space, enabling you to cache, download, and save content.

• With your consent, we can access your device information, using it as your device's unique identifier to provide you with more personalized recommendations, understand product applicability, identify irregularities, and ensure network and service security.

Exceptions to authorization:

According to relevant laws and regulations, your authorization is not required to collect your information in the following situations:

• Related to the fulfillment of obligations under applicable laws and regulations;

• Pertaining to public safety, public health, and significant public interests;

• Related to criminal investigation, prosecution, trial, and execution of judgments;

• When it is challenging to obtain your consent to protect the life, property, and other major legitimate rights and interests of you or other individuals;

• When the information collected is publicly disclosed by you;

• Information collected from legally disclosed sources, such as legal news, government information disclosure, and other channels;

• Necessary for signing a contract as per your request;

• Required to maintain the safe and stable operation of the service, such as detecting and handling product or service failures;

• Necessary for lawful news reporting;

• If an academic research institution uses the information for statistical or academic research in the public interest and de-identifies the information contained in the results;

• Other circumstances prescribed by laws and regulations.

Special notice on personal sensitive information:

Personal sensitive information refers to information that, if leaked, illegally provided, or misused, may endanger personal property safety and easily lead to damage to personal reputation, physical and mental health, or discriminatory treatment.

For example, ID card numbers, personally identifiable information (such as facial recognition, voiceprints, etc.), bank accounts, contact list information, communication records and content, property information, location information, total page browsing history, health physiological information, transaction information are all considered sensitive data. Please handle your sensitive data with care. You agree that we may process your sensitive data in accordance with this policy.

5. How We Use Cookies and Similar Technologies

We or our third-party partners may obtain and use your information through Cookies and similar technologies (e.g., Local Storage, Pixel, etc.) (collectively referred to herein as “Trackers”) and save this information as log information.

If you use the XI CHEN INTERNATIONAL LIMITED, Ltd application, based on your prior consent, we may collect resettable device identifiers, such as the “Google Advertising ID” on Android devices. These identifiers can be used like cookies to make online advertising more relevant and for analytics and optimization purposes.

6. Potential Sharing, Transferring, or Disclosure of Information

We may share, transfer, or disclose information:

• Sharing

  • We will not share your information with any third party outside of XI CHEN INTERNATIONAL LIMITED, Ltd without your consent, except in the following situations:

    • To provide you with our services. We may share your information with our partners and third parties to achieve essential functions or provide the services you need, such as payment services, data services.

    • To maintain and enhance our services. We may share your information with our partners and third parties to help us offer you more targeted and improved services.

    • To achieve the purposes described in Section 4 "How We Use Your Data."

    • To fulfill our obligations and exercise our rights under this Policy or other agreements between you and us.

    • Sharing with third parties, including partners who entrust us with marketing, but we will only provide information related to the reach and effectiveness of the promotion and will not provide any information that can identify you.

    • To comply with applicable laws and regulations, protect us and our affiliates or partners, you, other users, or public interests, property, or safety from harm, such as preventing fraud and other illegal activities and reducing credit risk.

    • To assist you in resolving disputes or conflicts with others as per your legal requirements.

    • To provide your information at your and/or your guardian's lawful request.

    • To provide your information based on academic research.

    • To provide your information in compliance with social and public interests as per applicable laws and regulations.

    • We will only share your information for lawful, legitimate, necessary, specific, and clear purposes. For companies, organizations, and individuals with whom we share information, we will sign strict Non-Disclosure Agreements and require them to handle information in accordance with our instructions, this policy, and any other relevant confidentiality and security measures.

• Transfer

  • As our business continues to evolve, we may engage in mergers, acquisitions, asset transfers, or similar transactions, and your information may be transferred as part of such transactions. We will require new companies and organizations that hold your information to continue to be bound by this Policy, or else we will request that the company and organization seek your authorization again.

  • With your affirmative consent, we will transfer your information to other parties.

• Disclosure

  • We will only disclose your information in the following circumstances, complying with industry-standard security measures:

    • Disclose your designated information with your affirmative consent according to your needs;

    • In cases where it is necessary to provide your information in accordance with applicable laws and regulations, mandatory administrative enforcement, or judicial requirements, we may disclose your information according to the type of information requested and the manner of disclosure. We will require the recipient to produce corresponding legal documents, such as subpoenas or investigation letters, and ensure that the information requested is as transparent as possible, legally valid, and limited to data obtained by law enforcement agencies for specific legal purposes.

• Exceptions to Authorization

  • In accordance with applicable laws and regulations, your authorization is not required for the collection, sharing, transfer, and disclosure of your information in the following cases:

    • Directly related to public safety, public health, or major public interests;

    • Directly related to criminal investigation, prosecution, trial, and execution of judgments;

    • When it is difficult to obtain your consent to protect the life, property, and other major legitimate rights and interests of you or other individuals;

    • The collected information is disclosed to the public by you;

    • Information collected from legally disclosed sources, such as legal coverage, government information disclosure, and other channels;

    • Fulfilling obligations stipulated by applicable laws and regulations;

    • Other circumstances prescribed by laws and regulations.

  • Sharing, transferring, and publicly disclosing de-identified (anonymous) Data where the recipient cannot re-identify the natural person will not be considered as sharing, transferring, and publicly disclosing personal information. We may store and process such data without prior notice or your consent.

7. How We Store, Preserve, and Protect Data

We retain your information only for the period required for the purposes described in this Policy and as required by applicable laws and regulations. If we terminate the service, we will stop collecting your personal information in compliance with applicable laws and regulations. After the service is terminated, we will delete or anonymize your personal information unless otherwise stipulated by laws or regulatory agencies.

The Data we collect and generate in the Services is stored in the United States or any other country in which we or our affiliates, partners, or service providers maintain facilities or business operations. You agree to authorize us to store and transfer your personal data across borders through this Policy. We will do so in compliance with the prevailing requirements of the GDPR, the CCPA where applicable. We will take measures to protect your information, including:

• Data security technical measures: We will adopt security protection measures in line with industry standards, including establishing reasonable system specifications and security technologies to prevent unauthorized access, modification, and loss or damage to your information.

• Other security measures: We manage and standardize the storage and use of information by establishing data security rules and conducting comprehensive data security control and awareness through monitoring and audit mechanisms.

• Employee and partner access: We only allow employees and partners who need to know your information to access it, and we have set up strict access control and monitoring mechanisms for this purpose.

• Reasonable precautions: We will take all reasonably practicable steps to ensure that irrelevant information is not collected.

• Internet environment: We will do our best to ensure the security of any information you send to us, but please be aware that the Internet environment is not 100% secure.

• Handling of security incidents: We have formulated systems to clarify the classification and grading standards of security incidents and the corresponding procedures, and we have established a special security incident emergency response team.

8. Your Right to Access, Correct, and Delete Data

We take all reasonable precautions to ensure that the Data we collect, retain, use, and disclose is accurate, complete, and up-to-date. However, the accuracy of that Data depends to a large extent on the Data you provide. You have the right to request access to, and correction of, your Data and we recommend that you:

• Let us know if there are any errors in your Data;

• Keep us up-to-date with changes to your Data.

If you wish to access or amend any of your Data we hold, or request that we delete any of your information that is no longer necessary for the provision of our Services, you may contact us in the manner as set forth under the “How to Contact Us” section.

9. Services Provided by Third Parties and Advertising/Payment Partners

The Services may link to social media or other services provided by third parties. You agree that third parties may directly collect and process your information if you use such services. We will evaluate the legality and necessity of such third parties to collect information and require them to take protective measures for your information.

10. Additional Information for California Residents (CCPA related)

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (the “CCPA”), provides certain verified California residents with specific rights. In regard to the CCPA, personal information is information that identifies, relates to, describes, is capable of being associated, or could reasonably be associated, directly or indirectly, with a particular California resident or household.

Information collected and sources of information

During the past 12 months, XI CHEN INTERNATIONAL LIMITED, Ltd collected the following categories of information about California residents. Not all information is collected about all individuals.

• Identifiers (such as profile name, profile image, email address, phone number, IP address, GAID/IDFA)

• Internet and other electronic network activity information (such as browsing history, search term, and information regarding a consumer’s interaction with an Internet website, application, or advertisement)

• Commercial information (top-up history, purchase history, subscription history, products/services purchased, obtained or considered, product preference)

• Geo-location data (Region information)

• Inference from the above (preferences, characteristics, behavior, attitudes, abilities, etc.)

Disclosure of personal information

During the past 12 months, XI CHEN INTERNATIONAL LIMITED, Ltd disclosed the following categories of information about California residents for a business purpose to the following categories of third parties. Business purposes are as follows:

Performing services for you:

• To create and manage user accounts;

• To assist you in completing a transaction or order;

• Processing third-party payment services;

• To offer our products and services to you in a personalized way, for example, we may provide suggestions based on your previous requests to enable you to identify suitable products and services more quickly;

• To notify you about changes to our services and products;

Advertising customization:

• For marketing and promotions;

Auditing relating to transactions, internal research and development:

• To provide internal business administration and operations;

• To measure the performance of marketing initiatives, ads;

Security detection, protection and enforcement; functionality debugging, error repair:

• As part of our efforts to keep our Sites safe and secure;

• To ensure the security of your account and our business, preventing or detecting fraud, malicious activity or abuses of our Sites

• To resolve disputes, to protect the rights, safety and interests of ourselves, our users or others, and to comply with our legal obligations.

Quality control

• To monitor quality control and ensure compliance with our legal obligations, codes and ordinances, policies and procedures.

Please note:

• We did not sell personal information. We did not share personal information for cross-context behavioral marketing purposes.

In addition, we use and may allow some ad networks and other third parties to collect information through our websites and services to determine how you interact with our websites and services, to identify your interests, create profiles and interest segments in order to provide advertising that is most relevant and useful to you.

Your CCPA rights

As a California resident, you have the right to request the following:

Information access rights

California residents have the right to request us to disclose certain information upon request about our information collection and disclosure practices. You also have the right to request a copy of the specific pieces of personal information we collected about you. You may make Information Access Requests up to twice during a 12-month period. Once we receive and confirm your verifiable request, we will disclose to you.

Information deletion rights

California residents have the right to request that we delete any of your personal information that we collected from them and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Information correction rights

California residents have the right to request that we correct information that we hold which is inaccurate. We will require that you provide information about yourself so that we can verify your identity before we can make any change in the information we hold about you and we will use commercially reasonable efforts to make the requested corrections.

Opt-out rights

We do not sell personal information.

Notice of financial incentives

We do not offer any such incentives at this time.

Non-discrimination

We do not discriminate against you as a result of your exercise of any of these rights.

If you would like to submit any type of request, seek information concerning the categories of personal information (if any) we share with third parties or affiliates for their direct marketing purposes, or have additional questions about the personal information we have about you, please contact us at: dramagotv@gmail.com

11. Retention of Personal Information

We will store personal information in a form which permits us to identify consumers, for as long as necessary for the purpose for which the personal information is processed. We may retain and use such personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically reasonably feasible to remove it. We retain information consumers provide in connection with requests made under the PDPO and GDPR for a period of five years.

12. Children’s Privacy Policy

XI CHEN INTERNATIONAL LIMITED, Ltd is made for the general public. We do not knowingly collect data from children as defined by applicable law without the prior consent from their parents or legal guardians or as otherwise permitted by applicable law. If you are a parent or guardian and you believe we have inadvertently collected information from your child or used/shared information from your child through our products and services without your consent, please contact us at dramagotv@gmail.com and we will remove the data to the extent required by applicable law.

13. Announcements and Amendments

This Privacy Policy may be amended from time to time and all handling of Data will be governed by the most recent version of this Privacy Statement, available on our website at Privacy Policy

14. How to Contact Us

For all issues and inquiries regarding our compliance with our obligations under the GDPR and CCPA where applicable, and any request for access to, correction or deletion of your Data, please contact us by email at dramagotv@gmail.com. To raise an issue regarding our handling of your Data, please contact us in order that we can attempt to resolve your issue.

These Terms are governed by the laws of the Hong Kong SAR.

Copyright © 2025 XI CHEN INTERNATIONAL LIMITED, Ltd Company. All rights reserved.