DramiShort Privacy Policy

This Privacy Policy explains how One Smart Technology Company Limited, a company incorporated in Hong Kong and doing business as "DramiShort" ("DramiShort", "we", "our", or "us"), collects, uses, discloses, stores, and protects information about you when you access or use the DramiShort short drama service made available through TikTok Minis (the "Services").

Please read this Privacy Policy carefully before using the Services or providing us with any Personal Information.

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. Where required by applicable law, we will obtain your consent before collecting or processing your Personal Information for purposes that require consent.

If you do not agree with this Privacy Policy, please discontinue your use of the Services.

This Privacy Policy applies specifically to the DramiShort service made available through TikTok Minis and does not govern TikTok's own collection, use, or processing of your information. Your use of TikTok is separately governed by TikTok's applicable terms and privacy policies.

Note to Residents of the European Economic Area and the United Kingdom

If you are located in the European Economic Area ("EEA") or the United Kingdom ("UK"), we process your Personal Information in accordance with applicable data protection laws, including the General Data Protection Regulation ("GDPR") and the UK GDPR, where applicable.

This Privacy Policy describes the categories of Personal Information we collect, the purposes for which we process it, the legal bases for processing, and certain rights that may be available to you.

1. Personal Information We Collect

The categories of Personal Information we collect depend on how you use the Services, the features you access, and the requirements of applicable law.

We may collect information:

directly from you;

automatically when you use the Services;

from TikTok or other authorized third-party service providers; and

from other sources where permitted by applicable law.

We only collect information that is reasonably necessary for the purposes described in this Privacy Policy.

1.1 Information You Provide to Us

Depending on the features you use, you may provide us with information such as:

your email address or other contact information when you contact customer support;

information you provide when submitting a request, complaint, or other communication to us;

information relating to your preferences or interactions with the Services; and

other information you voluntarily provide to us.

We do not require you to provide Personal Information that is not necessary for the particular feature or service you are using.

1.2 Information We Receive Through TikTok

Because DramiShort is made available through TikTok Minis, we may receive certain information from TikTok when you access or use the Services.

Depending on the TikTok functionality and permissions used by DramiShort, this may include:

a TikTok-related unique identifier such as an OpenID associated with your use of the Mini Drama;

authentication and authorization information;

username or display name, where you have provided the required authorization;

profile avatar, where you have provided the required authorization; and

information necessary to support transactions or other TikTok Mini Drama functionality.

The specific information made available to us depends on the TikTok permissions and capabilities that DramiShort has implemented and the authorization you provide.

TikTok Minis currently supports authentication through TikTok's Mini Drama login capabilities. Basic identification may be obtained through silent login, while additional profile information such as username and avatar may require explicit authorization.

1.3 Information Collected Automatically

When you access or use the Services, we and our service providers may automatically collect certain technical and usage information, such as:

IP address;

device type and operating system;

browser or application environment;

device and network information;

language and time zone;

approximate location derived from IP address;

information about your interactions with the Services;

pages, screens, dramas, episodes, and features you access;

viewing and interaction information;

session information;

crash reports, diagnostic information, and performance data; and

other technical information reasonably necessary to operate, secure, maintain, and improve the Services.

We may use cookies, local storage, SDKs, pixels, web beacons, and similar technologies where applicable to provide, maintain, analyze, and improve the Services.

1.4 Cookies and Similar Technologies

We may use cookies and similar technologies to:

maintain sessions;

remember preferences;

understand how users interact with the Services;

measure the performance of the Services;

detect and prevent fraud or abuse;

improve functionality and performance; and

provide relevant content and advertising where applicable and permitted by law.

You may be able to control certain cookies and similar technologies through your device, browser, or the relevant platform settings. Disabling certain technologies may affect the availability or functionality of some features.

1.5 Information Relating to Purchases and Subscriptions

If you purchase a subscription, virtual currency, digital content, or other paid products through the Services, we may receive transaction-related information from TikTok or an authorized payment service provider.

This may include:

transaction or order identifiers;

product or subscription information;

transaction amount and currency;

transaction status;

subscription start and expiration information;

renewal or cancellation information; and

other information necessary to verify and fulfill the transaction.

Payment card details and other sensitive payment credentials may be processed directly by the applicable payment provider rather than by us.

TikTok Minis currently supports in-app purchases through TikTok Beans and recurring subscriptions.

1.6 Information from Other Sources

We may receive information about you from other sources where permitted by applicable law, including:

TikTok and its affiliated services;

payment and transaction service providers;

service providers that support our Services;

analytics and security providers;

advertising and marketing partners, where applicable; and

publicly available sources.

The information we receive from these sources depends on the services involved and the permissions, contracts, or other legal bases applicable to the relevant processing.

2. How We Use Your Information

We may use Personal Information for the following purposes.

2.1 Providing and Operating the Services

We may use your information to:

provide and operate the Services;

authenticate and manage your account or session;

provide access to dramas, episodes, and other Content;

remember your viewing progress and preferences;

provide personalized recommendations and content;

provide customer and technical support;

process and fulfill purchases and subscriptions;

communicate with you about the Services;

maintain and improve the functionality and performance of the Services; and

provide features and services that you request.

2.2 Administrative and Operational Purposes

We may use your information to:

maintain network and information security;

detect, investigate, and prevent fraud, abuse, unauthorized access, and other unlawful activities;

monitor and analyze Service performance;

identify and resolve errors and technical problems;

conduct internal audits and quality control;

enforce our Terms of Use and other applicable policies;

protect the rights, property, safety, and security of DramiShort, our users, and others; and

comply with applicable laws, regulations, legal processes, and governmental requests.

2.3 Improving Our Services

We may use information to understand how users interact with the Services and to:

analyze usage trends;

improve existing features;

develop new features and products;

improve content recommendations;

conduct research and analysis;

improve user experience; and

measure the effectiveness of our Services.

Where appropriate, we may use aggregated or de-identified information for these purposes.

2.4 Marketing and Advertising

Where permitted by applicable law, we may use certain information to:

communicate with you about our Services;

provide information about new features or promotions;

measure and improve marketing campaigns; and

provide or support advertising within the Services.

We do not sell your Personal Information.

Where applicable law requires consent for personalized advertising or similar processing, we will obtain the required consent or provide the legally required choice mechanism.

We do not use Personal Information for purposes that are incompatible with the purposes described in this Privacy Policy without providing any notices or obtaining consent required by applicable law.

2.5 Legal and Compliance Purposes

We may process Personal Information where necessary to:

comply with applicable laws and regulations;

respond to lawful requests from governmental authorities;

establish, exercise, or defend legal claims;

enforce our agreements and policies; and

protect against fraud, security threats, or other unlawful activities.

3. Legal Bases for Processing

If you are located in the EEA, UK, or another jurisdiction where a legal basis is required, we rely on one or more of the following legal bases:

Performance of a Contract

We may process your Personal Information where it is necessary to provide the Services you request or to perform our contractual obligations to you.

Legitimate Interests

We may process information where necessary for our legitimate interests, including:

operating and improving the Services;

maintaining security;

preventing fraud and abuse;

understanding Service usage;

protecting our legal rights; and

managing our business.

When relying on legitimate interests, we consider and balance our interests against your rights and freedoms.

Consent

We may process Personal Information based on your consent where required by applicable law.

You may withdraw your consent at any time where applicable, although withdrawal will not affect the lawfulness of processing conducted before withdrawal.

Legal Obligations

We may process Personal Information where necessary to comply with a legal obligation.

Vital Interests

Where permitted by applicable law, we may process Personal Information where necessary to protect the vital interests of you or another person.

4. How We Disclose Your Information

We do not sell your Personal Information.

We may disclose Personal Information in the circumstances described below.

4.1 Service Providers

We may share Personal Information with trusted vendors and service providers that perform services on our behalf, including providers supporting:

hosting and cloud infrastructure;

content delivery;

payment processing;

customer support;

analytics;

security and fraud prevention;

technical support;

data storage;

communications; and

other business operations.

These providers may access, process, or store Personal Information only as necessary to provide services to us and subject to applicable contractual and legal requirements.

4.2 TikTok

Because DramiShort operates through TikTok Minis, certain information may be exchanged with TikTok as necessary to:

authenticate users;

enable TikTok Mini Drama functionality;

process transactions;

provide platform services;

maintain platform security; and

comply with TikTok's platform requirements.

TikTok may separately collect and process information in accordance with its own privacy policies and terms.

4.3 Payment and Transaction Providers

We may disclose transaction-related information to payment providers or other service providers to:

process purchases;

verify transactions;

prevent fraud;

manage subscriptions;

process refunds where applicable; and

provide transaction support.

4.4 Analytics and Technology Providers

We may use third-party analytics, performance monitoring, crash reporting, security, and technology services to understand and improve the Services.

Where such providers process Personal Information on our behalf, they are required to process the information in accordance with applicable contractual and legal requirements.

4.5 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of assets, or other corporate transaction, Personal Information may be disclosed to relevant parties as part of that transaction.

Where required by applicable law, we will provide appropriate notice and take reasonable steps to protect Personal Information during such transactions.

4.6 Legal Requirements

We may disclose Personal Information where we reasonably believe disclosure is necessary to:

comply with applicable laws or legal processes;

respond to lawful requests from governmental authorities;

protect our rights or property;

protect the safety of our users or the public;

investigate fraud or other unlawful activity; or

establish, exercise, or defend legal claims.

5. Data Retention

We retain Personal Information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including:

providing the Services;

maintaining account and transaction records;

complying with legal and regulatory obligations;

resolving disputes;

enforcing agreements; and

preventing fraud and abuse.

Retention periods may vary depending on the type of information, the purpose for which it was collected, and applicable legal requirements.

When Personal Information is no longer required, we will delete, anonymize, or otherwise dispose of it in accordance with applicable laws and our data retention practices.

6. Data Security

We take reasonable technical and organizational measures designed to protect Personal Information against unauthorized access, disclosure, alteration, loss, misuse, or destruction.

These measures may include access controls, authentication mechanisms, encryption where appropriate, monitoring, security testing, and other safeguards.

However, no method of transmission or storage is completely secure. We therefore cannot guarantee the absolute security of your Personal Information.

7. International Data Transfers

Because we operate internationally and may use service providers located in different countries, your Personal Information may be transferred to, stored in, or processed in countries outside the country in which you reside.

Where required by applicable law, we will implement appropriate safeguards for international data transfers.

For users in the EEA, UK, or other jurisdictions with applicable cross-border transfer requirements, such safeguards may include standard contractual clauses or other legally recognized transfer mechanisms.

8. Your Privacy Rights

Depending on where you live and subject to applicable law, you may have certain rights regarding your Personal Information.

These rights may include:

the right to access your Personal Information;

the right to correct inaccurate or incomplete information;

the right to request deletion of your Personal Information;

the right to restrict certain processing;

the right to object to certain processing;

the right to receive your Personal Information in a portable format;

the right to withdraw consent where processing is based on consent; and

the right to lodge a complaint with a relevant data protection authority.

To exercise applicable rights, please contact us using the contact information provided below.

We may need to verify your identity before completing certain requests.

9. Children's Privacy

The Services are not intended for individuals under 16 years of age.

We do not knowingly collect Personal Information from individuals under 16 where prohibited by applicable law.

If you believe that a child under the applicable minimum age has provided Personal Information to us, please contact us at:

artu_developer@ujumedia.com

If we become aware that we have collected Personal Information from a child in circumstances where such collection is prohibited, we will take reasonable steps to delete the information in accordance with applicable law.

10. Third-Party Services

The Services may rely on or interact with third-party services, including TikTok and service providers supporting authentication, payments, analytics, advertising, hosting, security, and other functionality.

These third parties may independently collect and process information in accordance with their own privacy policies.

Examples may include:

TikTok

TikTok's services and platform may process information when you use TikTok or interact with DramiShort through TikTok Minis.

Google / Firebase

Where applicable, we may use Google or Firebase services for analytics, infrastructure, security, or other technical functions.

Meta / Facebook

Where applicable, we may use Meta or Facebook services for advertising, analytics, or other business purposes.

The specific third-party services used by DramiShort may change over time.

You should review the privacy policies of the relevant third parties for more information about their data practices.

11. Your Choices

Depending on the features available to you and applicable law, you may have choices regarding:

Account and Profile Information

You may contact us to request correction or deletion of certain information associated with your account.

Marketing Communications

If we send you marketing communications, you may opt out by following the unsubscribe instructions included in those communications or by contacting us.

Personalized Advertising

Where applicable, you may be able to manage personalized advertising through available platform, device, or service settings.

TikTok Permissions

Certain information obtained through TikTok may depend on permissions or authorization granted through TikTok. You may manage applicable permissions through the relevant TikTok settings or authorization mechanisms where available.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to:

our Services;

our data practices;

applicable laws and regulations;

third-party services; or

platform requirements.

When we make material changes, we may provide additional notice where required by applicable law.

The updated Privacy Policy will be posted through the Services with a revised "Last Updated" date.

We encourage you to review this Privacy Policy periodically.

13. Contact Us

If you have any questions, concerns, requests, or complaints regarding this Privacy Policy or our privacy practices, please contact us at:

One Smart Technology Company Limited

Email: artu_developer@ujumedia.com

Hong Kong