Privacy Policy

Updated on: October 16, 2025

Applicable to: All users of NovelClip, including users in the European Union (EU) and European Economic Area (EEA)

Xiamen Mikailai Technology Co., Ltd. (hereinafter referred to as "we", "us", or "our"), the operator of NovelClip, is committed to protecting your personal data in compliance with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679), other applicable EU privacy laws, and local laws of your country/region. This Privacy Policy explains how we collect, use, store, transfer, and protect your personal data when you use NovelClip's services (including Google Login functionality). By downloading, installing, or using NovelClip, you acknowledge that you have read, understood, and agreed to the collection and processing of your personal data in accordance with this Policy. If you do not agree, please do not use our services.

1. Legal Basis for Data Processing (GDPR Article 6)

We process your personal data only on the following legal bases required by GDPR:

a. Consent (Article 6(1)(a)): We process your data when you explicitly authorize specific functions (e.g., storage permission, third-party SDK services including Google Login). You may withdraw consent at any time without affecting the legality of processing before withdrawal.

b. Performance of a Contract (Article 6(1)(b)): Processing is necessary to fulfill the service agreement with you (e.g., collecting device information to ensure NovelClip's operation, processing payment data to complete transactions, using Google Login to authenticate your account).

c. Legitimate Interests (Article 6(1)(f)): Processing is necessary for our legitimate business interests (e.g., improving service stability, optimizing user experience), provided that your fundamental rights and freedoms do not override such interests.

d. Compliance with Legal Obligations (Article 6(1)(c)): Processing is required to comply with applicable laws (e.g., responding to legal inquiries from competent authorities).

2. Permission Description

File reading/writing permissions are not enabled by default. They will only be used when specific functions or services are realized with your explicit authorization, and you may withdraw the authorization at any time through your device settings:

1. Granting storage permission: To save downloaded media files and edited content.

2. Reading the contents of the memory card: To confirm that edited files can be saved to the memory card.

3. Modifying or deleting contents in the memory card: To handle temporary fragmented files generated during the download process.

4. Google Account authorization (optional): To enable Google Login functionality, we request access to your basic Google Account information (name, email address, profile photo) with your explicit consent. This permission is only used for account authentication and will not be used for other purposes without your consent.

3. Collection and Use of Personal Information

3.1 Types of Personal Data Collected

3.2 Changes in Data Processing Purpose

As our business develops, the functions and services of NovelClip may be adjusted. If we need to process your personal data (including Google Login data) for a new purpose unrelated to the original one, we will inform you of the new purpose and legal basis, and obtain your consent if required by law.

3.3 Exceptions for Non-Consensual Processing

In the following circumstances, we may collect/use your personal data without your consent in accordance with laws and regulations:

a. Directly related to national security and national defense security;

b. Directly related to public security, public health, and major public interests;

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

d. Necessary to protect the major legitimate rights and interests of you or other individuals (e.g., life, property) where obtaining consent is impracticable;

e. Personal data you have publicly disclosed to the public;

f. Personal data collected from legally publicly disclosed sources (e.g., legal news reports, government information disclosure);

g. Necessary for signing or performing a contract at your request;

h. Necessary for maintaining the safe and stable operation of NovelClip (e.g., detecting and fixing faults);

i. Other circumstances stipulated by laws and regulations.

4. Cookies and Similar Technologies

We use cookies and similar technologies (e.g., web beacons) to enhance your user experience (including maintaining Google Login session state). You have the right to accept or refuse cookies by modifying your device/browser settings. Disabling cookies may affect some functions of NovelClip (e.g., login services including Google Login). All data collected through cookies is subject to this Policy.

5. Sharing, Transfer, and Public Disclosure of Personal Data

5.1 Sharing Principles

a. Authorization and Consent: We will not share your personal data (including Google Login data) with third parties without your explicit consent, unless the data is de-identified and cannot be linked back to you.

b. Security and Prudence: We evaluate third-party partners' data security capabilities and sign Data Processing Agreements (DPAs) to ensure they comply with GDPR and protect your data (including Google Login data).

5.2 Payment Function Sharing

The payment function is provided by third-party payment institutions. These institutions may collect your name, bank card details, and mobile phone number (sensitive personal data) to complete transactions. Refusing to provide this data will prevent you from using the payment function but will not affect other features of NovelClip (including Google Login).

5.3 Cross-Border Data Transfer (GDPR Article 48)

We store your personal data (including Google Login data) within the People's Republic of China. If we transfer data to countries/regions outside the EU/EEA, we will ensure compliance with GDPR by:

• Transferring to countries recognized by the European Commission as having an adequate level of data protection;

• Using Standard Contractual Clauses (SCCs) approved by the European Commission;

• Obtaining your explicit consent for the transfer (if required).

Note: Google Login data is processed by Google in accordance with Google's Privacy Policy (https://policies.google.com/privacy), and Google's cross-border data transfer complies with GDPR requirements.

5.4 Public Disclosure

We will not publicly disclose your personal data (including Google Login data) unless required by law or with your explicit consent. We will adopt industry-standard security measures for any public disclosure.

6. Data Storage and Security

6.1 Storage Period

We retain your personal data (including Google Login data) only for the period necessary to provide NovelClip services or as required by law. After the retention period expires, we will securely delete or anonymize your data (anonymized data is no longer considered personal data under GDPR). Google Login data is retained only for the duration of your account existence (until account cancellation).

6.2 Security Measures

We implement technical and organizational security measures to protect your data (including Google Login data) against unauthorized access, disclosure, alteration, or destruction:

• Encryption of data in transit (TLS 1.2+) and at rest;

• Access control (only authorized personnel can access personal data);

• Regular security audits and vulnerability scans;

• Data breach response procedures (see Section 9).

7. Your Rights as a Data Subject (GDPR Chapter III)

In accordance with GDPR, you have the following rights regarding your personal data (including Google Login data). To exercise these rights, contact us via the channels in Section 12:

a. Right to Access: Request confirmation of whether we process your data and obtain a copy of your personal data (including Google Login data);

b. Right to Rectification: Request correction of inaccurate/incomplete personal data (including Google Login data);

c. Right to Erasure ("Right to be Forgotten"): Request deletion of your data if it is no longer necessary, you withdraw consent, or processing violates GDPR (including deletion of linked Google Login data);

d. Right to Restriction of Processing: Request restriction of processing (e.g., if you dispute the accuracy of the data);

e. Right to Data Portability: Request your data (including Google Login data) in a structured, machine-readable format (e.g., CSV/JSON) or direct transmission to another controller;

f. Right to Object: Object to processing based on legitimate interests or for direct marketing;

g. Right to Withdraw Consent: Withdraw any prior consent for data processing (including Google Login authorization) at any time (no impact on prior legal processing).

We will respond to your request within 1 month (may extend by 2 months for complex requests) and verify your identity to prevent unauthorized access.

8. Third-Party SDKs

We integrate third-party SDKs to provide specific services (including Google Login). These SDKs may collect your personal data, and we have signed DPAs with providers to ensure GDPR compliance:

9. Data Breach Notification (GDPR Article 33)

If a personal data breach (including Google Login data) is likely to result in a high risk to your rights and freedoms, we will:

• Notify the relevant EU Data Protection Authority (DPA) within 72 hours of discovering the breach;

• Notify you without undue delay (if the breach poses a high risk to your privacy), including details of the breach, potential risks, and remedial measures.

10. Minors' Data Protection (GDPR Article 8)

If you are under 16 years old (or the minimum age required by your country/region), you must obtain parental/guardian consent before using NovelClip (including Google Login functionality). We will not knowingly collect personal data (including Google Login data) from minors without valid consent. If we discover unauthorized collection of minors' data, we will delete it immediately. Guardians may contact us to exercise rights regarding the minor's data.

11. Account Cancellation

You can cancel your NovelClip account via: [My Page] → [System Settings] → [Cancel Account]. After successful cancellation:

• We will stop providing services to you (including revoking Google Login authorization);

• We will delete or anonymize your personal data (including Google Login data) in accordance with GDPR (excluding data retained for legal obligations);

• Account cancellation is irreversible—please back up your data before proceeding.

12. How to Contact Us

If you have questions, complaints, or requests regarding this Policy or your personal data (including Google Login data), contact us via:

• Email: 1065494705@qq.com

• Mailing Address: [Add your company's full physical address here]

If you are not satisfied with our response, you have the right to lodge a complaint with the Data Protection Authority (DPA) of your country/region (list of EU DPAs: https://ec.europa.eu/info/law/law-topic/data-protection/publications/authorities-country_en). For Google Login-related privacy issues, you may also contact Google via https://support.google.com/accounts/answer/27441.

13. Policy Updates

We may update this Policy to comply with legal changes or service adjustments (including changes to Google Login functionality). We will notify you of material changes via:

• Pop-up notification in NovelClip;

• Email to your registered address (including Google Account email if applicable);

• Prominent notice on the NovelClip homepage.

The updated Policy will take effect on the stated "Updated on" date. Your continued use of NovelClip (including Google Login) after the update constitutes acceptance of the new Policy. We will not reduce your rights under this Policy without your explicit consent.