This Privacy Policy (the "Policy") describes how we collect, use, disclose, store, and protect your personal data when you use the AllinNovel platform, including our websites, mobile applications, and related services (collectively, the "Platform" or "Services").
The Platform is provided and controlled by APTECH CREATIVE PTE. LTD., registered in Singapore (registered address: 91 Bencoolen Street, #12-03, Sunshine Plaza, Singapore 189652) ("we", "us", or "our"). If you have any questions about how we use your personal data, please contact us at [email protected].
By using the Services, you confirm that you have read and understood this Privacy Policy, and agree to the processing of your personal data in accordance with this Policy. If you do not agree with this Policy, please do not use the Services. This Policy, together with our Terms of Use, forms the complete agreement between you and AllinNovel.
THIS PRIVACY POLICY IS IMPORTANT. WE HOPE YOU WILL TAKE THE TIME TO READ IT CAREFULLY.
1. Data Collection
The types of data we collect and process depend on how you use AllinNovel. Even if you do not have an account, we may still collect some data about you when you use the Services.
1.1 Information You Provide
Account Information (username, nickname, age, email, password, profile photo); User Content (novels, comments, and metadata); Payment Information (as necessary for transactions; credit card data is provided directly to third-party processors); Contact Information and Feedback; Survey responses.
1.2 Information We Collect Automatically
Device and browser information (browser type, language, time zone, cookie data, device identifiers including IDFA, IDFV, Android Advertising ID, device type, model, manufacturer, OS, carrier, screen size, battery, memory, settings, boot time); Network information (IP address, crash reports, system activity, request date/time/referrer URL); Usage data (app events, purchase history, top-up records, bonus information, bookmarks, bookshelf management, sharing, searches, etc.).
1.3 Information from Third Parties
Social networks (if you register via Facebook, Google, Apple, etc.); advertising partners and advertising networks; business partners and suppliers.
1.4 Non-Personal Data
Non-Personal Data refers to data that cannot be used to identify an individual. We keep your Personal Data and Non-Personal Data separate and use each independently.
1.5 Specially Protected Data
You may choose to provide information such as your age, gender, address, and email address. These may be specially protected under the laws of your jurisdiction.
2. Cookies and Similar Technologies
Cookies are small pieces of text used to store data on web browsers. We also use other similar technologies. In this Policy, we refer to all of these technologies as "Cookies." We use Cookies to: verify login information; track traffic flow; understand visitor numbers and device types; monitor service performance; customize your experience; and provide customer service.
You have the right to choose whether to accept Cookies. If you refuse Cookies, certain features may not function properly. For iOS and Android devices, you can also limit tracking or reset your advertising ID through operating system settings.
3. Purposes and Legal Basis of Data Processing
AllinNovel uses your data to perform our contract with you, provide the Services, process transactions, communicate with you, and comply with law. We may also use your data with your consent and for our legitimate business interests. Specifically:
- Creating and maintaining your account and personal profile;
- Providing, administering, and personalizing the Services, including content recommendations, commenting features, and paid content;
- Processing your transactions and payments;
- Communicating service updates, product announcements, promotions, and marketing information (based on prior consent);
- Detecting, preventing, and combating fraud, abuse, and illegal activities; monitoring and preventing spam; anti-piracy operations;
- Developing, researching, and testing service improvements;
- Measuring advertising effectiveness and delivering targeted advertising;
- Enforcing our terms, conditions, and policies, and meeting legal obligations;
- Cross-border transfer, storage, or processing of your data as necessary for the Services.
3.1 Deemed Consent
Pursuant to Section 15 of the Singapore Personal Data Protection Act ("PDPA"), you will be deemed to have consented to our collection, use, or disclosure of your personal data in the following circumstances:
- Deemed Consent by Contractual Necessity: Where you provide personal data in connection with entering into or performing a contract with AllinNovel, you are deemed to have consented to our use of such data for the purposes of contract performance, including disclosure to necessary third-party service providers.
- Deemed Consent by Notification: Where we intend to use your personal data for a new purpose, we will notify you of the intended purpose and your opt-out method. If you do not object within the reasonable period specified, you will be deemed to have consented to such use.
3.2 Legitimate Interests Exception
Pursuant to Paragraph 5, Part 3 of the First Schedule to the PDPA, we may collect, use, or disclose your personal data without your consent where our legitimate interests (or those of another person) outweigh any adverse effect on you. We will conduct a risk assessment and implement reasonable measures to eliminate or mitigate any adverse effects before relying on this exception. Such legitimate interests include but are not limited to: ensuring platform security and integrity; preventing fraud and abuse; enforcing our terms and policies; and obtaining legal services.
3.3 Business Improvement Exception
Pursuant to Section 17A of the PDPA, we may use your personal data without your consent for the following business improvement purposes, provided a reasonable person would consider such use appropriate:
- Improving, enhancing, or developing new goods, services, or business process methods;
- Understanding and analyzing user behavior and preferences in relation to our goods and services (including A/B testing, recommendation algorithm optimization, etc.);
- Identifying, personalizing, or customizing suitable goods or services for users.
The above business improvement purposes do not include making decisions that are likely to have a significant adverse effect on you. We may also share personal data with affiliates for the above purposes to the extent permitted under the PDPA.
4. Data Sharing
We will never sell your personal data. Except with your consent or as otherwise described in this Policy, we do not share your personal data. Specifically:
- Service Providers: We engage other companies and individuals to provide services to us (such as cloud storage, payment processing), requiring them to provide equal protection of user data.
- Affiliates: We may share your information with members, subsidiaries, or affiliates of our corporate group.
- Advertising Partners: We do not provide any personally identifiable information to third-party ad servers without your consent.
- Other Users: Any information in your publicly visible profile will be visible to all other users.
- Government and Law Enforcement: We may release your information as required by law.
- Business Asset Transactions: Pursuant to Section 15B of the PDPA, in connection with any merger, acquisition, restructuring, or sale of assets, we may transfer your personal data as part of the business assets to the successor without requiring separate consent from each individual user. The successor will be bound by this Policy or a policy providing equivalent protection.
- Third-Party Plug-ins: Third-party applications and platforms may allow you to post information about your activities on the Services to your social networks. This Policy does not apply to your use of such third-party applications.
5. Data Storage and Cross-Border Transfer
If you choose to use the Services or provide information to us, your information may be transferred to, processed, and maintained on servers or databases located outside of your country or jurisdiction. By submitting your information, you agree to this transfer, storing, or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Policy and applicable law.
5.1 Extraterritorial Enforcement Cooperation
With respect to data access requests, enforcement demands, or judicial assistance requests from jurisdictions outside Singapore, AllinNovel retains sole discretion in determining whether to cooperate. AllinNovel will only cooperate with such extraterritorial requests to the extent required or permitted by Singapore law. Under no circumstances will AllinNovel disclose your personal data solely on the basis of a request from a foreign enforcement authority where such disclosure is not required or permitted by Singapore law.
6. Data Security
We take appropriate security measures, such as encryption, to protect the confidentiality of your personal data during transmission and in storage. We restrict access to your personal information to staff who need to know that information to operate, develop, or improve the Services.
We recommend that you use a strong password and never share your password with anyone. Although we make good faith efforts to ensure data security, no method of transmission over the internet is 100% secure. Any data transmission is at your own risk.
6.1 Data Breach Notification
AllinNovel commits to comply with the data breach notification requirements under Section 26D of the PDPA, including notifying the Personal Data Protection Commission ("PDPC") and affected individuals within the legally required timeframes when a notifiable data breach occurs. However, AllinNovel shall not assume liability for the data breach event itself beyond what is required by applicable law. AllinNovel shall not bear direct liability for data breaches caused by the acts or omissions of third-party service providers, but will assist with investigation and response within reasonable bounds.
7. Your Rights
We provide tools for viewing, managing, downloading, and deleting your personal data. Your rights include:
- Right of Access: You have the right to access the personal data we hold about you.
- Right of Rectification: You have the right to correct your personal data at any time.
- Right of Deletion: You can request deletion of your personal data or account.
- Right to Restriction and Portability: You have the right to request restriction of processing and data portability.
- Right to Withdraw Consent: You have the right to withdraw consent at any time.
To exercise these rights, please contact us at [email protected]. We will respond within thirty (30) calendar days of receiving your request. If the request is particularly complex, we may extend the processing period by up to two (2) additional months, with prior notice to you.
7.1 Consequences of Consent Withdrawal
You have the right to withdraw your consent for our collection, use, or disclosure of your personal data at any time. However, please understand that withdrawal of consent may result in our inability to continue providing part or all of the Services to you. We will inform you of the specific consequences of withdrawal when processing your request. AllinNovel shall not be liable for any service interruption or feature unavailability resulting from your withdrawal of consent. Withdrawal of consent does not affect our right to continue processing your personal data on other legal bases (such as legitimate interests, legal obligations, or the business improvement exception).
7.2 Right to Refuse Data Requests
In accordance with the PDPA, AllinNovel has the right to refuse to process data access or correction requests that are: frivolous or vexatious; manifestly unfounded or excessive; likely to damage the privacy rights of others; impractical; requiring disproportionate technical effort; not required under local law; or relating to information that is publicly available or provided under confidential conditions. AllinNovel may also reject requests where granting access or deletion would impair our ability to use the relevant information for anti-fraud and security purposes. For repetitive or abusive requests, AllinNovel reserves the right to charge a reasonable fee.
8. Deletion of Your Data
You may request deletion of your personal data at any time through the following methods:
- Search for and delete certain personal data (e.g., remove books from bookshelf, delete comments).
- Permanently delete your account via Me > Settings > Terms and Policy > Delete My Account, or contact us at [email protected].
Once your account is deleted, you will not be able to reactivate it or retrieve your reading records, spending records, unlock records, or top-up balance. Processing of account deletion requests shall not exceed thirty (30) calendar days from the date of receipt. If the request is particularly complex, we may extend the processing period by up to two (2) additional months, with prior notice to you.
9. Data Retention
We retain your information for as long as your account is active or as needed to provide you with the Services. Even after you delete your account or withdraw consent, we may retain necessary data for the following legitimate purposes:
- Compliance with legal obligations (including but not limited to tax, anti-money laundering, and audit obligations);
- Enforcement and maintenance of our terms and policies;
- Dispute resolution and ongoing legal proceedings;
- Prevention of fraud and abuse;
- Maintenance of platform security and integrity;
- Establishment, exercise, or defense of legal claims.
Retention periods are determined by AllinNovel based on the necessity of the above purposes. After account deletion, we may retain certain data in aggregated and anonymized form.
10. Anonymized Data and Derived Data
10.1 Anonymized and Aggregated Data
Information that has been anonymized or aggregated so that it no longer constitutes personal data is not subject to the restrictions of the PDPA. AllinNovel may use, disclose, and commercialize such information without restriction, including but not limited to industry analysis, trend reports, advertising effectiveness reports, statistical research, and public demonstration of service usage trends.
10.2 Derived Data
AllinNovel may derive or generate new data based on your personal data in the course of providing the Services ("Derived Data"), such as reading preference tags, user classifications, and recommendation scores. Pursuant to the PDPA amendments, AllinNovel holds independent processing rights over Derived Data. You may not request correction of any errors or omissions in Derived Data, and AllinNovel is not required to transmit Derived Data in response to data portability requests.
11. Automated Decision-Making
The Platform uses algorithmic systems to recommend content, personalize displays, and perform other automated processing. AllinNovel accepts no liability for the results of automated decision-making, including but not limited to any content you are exposed to or miss as a result of algorithmic recommendations or personalized display.
The Singapore PDPA does not currently grant individuals the right to require human review of automated decisions. Accordingly, you do not have the right to demand that AllinNovel conduct a human review solely because you are dissatisfied with the results of automated processing. The operation of algorithmic systems does not constitute any promise, warranty, or representation by AllinNovel.
12. Third-Party Personal Data in User Content
User Content you publish on the Platform (including but not limited to novels, comments, and other materials) may contain the personal data of third parties. You represent and warrant that: (a) your content does not contain unauthorized third-party personal data; and (b) you have obtained all necessary authorizations and consents for any third-party personal data included in your content. If AllinNovel incurs any liability, loss, cost, or claim as a result of your breach of this Section, you agree to indemnify AllinNovel in accordance with Section 11 of the Terms of Use. AllinNovel does not assume data controller liability under the PDPA for third-party personal data contained in User Content.
13. Age Restrictions
AllinNovel is not intended for children under the age of 16. If AllinNovel discovers that a user under 16 has created an account or posted personally identifiable information, AllinNovel will terminate the account and remove the information as soon as commercially practicable. Users between 16 and 18 must have their parent or legal guardian agree to this Policy and use the Services under such parent or guardian's supervision and permission. If you believe that we have personal data about or collected from a child under the relevant age, please contact us at [email protected].
14. Third-Party Advertisers and Links
AllinNovel allows third-party advertisers and advertising networks to serve advertisements within the Services. If you do not wish to receive targeted advertising, you can disable personalized advertisements by going to Me > Settings > Terms and Policy > Customized Ads Recommendation. iOS and Android operating systems also provide options to limit tracking and/or reset advertising IDs. Turning off personalized advertisements may not necessarily reduce the number of advertisements you receive. You should consult the respective privacy policies of third-party advertisers.
15. Changes to This Policy
We may change this Privacy Policy from time to time. We will not reduce your rights without your explicit consent and will always indicate the last modification date. For material changes, we will notify you via inbox message or website posting. For changes required for security, legal, or regulatory purposes, we may not be able to provide advance notice. IF YOU CONTINUE TO USE THE SERVICES AFTER THE UPDATED POLICY HAS BEEN POSTED, WE WILL CONSIDER THAT YOU HAVE ACCEPTED THE UPDATED POLICY.
16. Regional Addenda
16.1 Special Terms for United States Users
We may send direct marketing information via email. You can unsubscribe via Me > Settings > Terms and Policy > EDM Subscribe, or through the "unsubscribe" link in each email. California residents have CCPA privacy rights as detailed in Section 17.2 of the Terms of Use.
16.2 Special Terms for EU and UK Users
If you are a resident of the EU or UK, you have rights under the GDPR including rights of access, rectification, erasure, restriction, portability, objection, and automated decision-making, as detailed in Section 17.1 of the Terms of Use.
16.3 Special Terms for Mainland China Users
If you are a resident of the People's Republic of China (mainland), you understand and expressly consent that your personal information will be transferred to and processed in jurisdictions outside the PRC, as detailed in Section 17.3 of the Terms of Use.
16.4 Special Terms for Australian Users
If you are a resident of Australia, the following additional provisions apply:
- Consumer Guarantees: The Australian Consumer Law (Schedule 2 to the Competition and Consumer Act 2010) provides you with consumer guarantees that cannot be excluded, restricted, or modified. Nothing in this Policy excludes, restricts, or modifies any right or remedy you may have under the Australian Consumer Law.
- Data Protection: Your personal information is protected under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Although Australia does not currently have a general right to personal data deletion on request, under APP 11, we will take reasonable steps to destroy or de-identify your personal information when it is no longer needed for its original purpose. We will monitor the progress of Privacy Act reforms and adjust our practices accordingly.
- Limitation of Liability: To the extent permitted by law, AllinNovel limits its liability for failure to comply with any applicable consumer guarantee under the Australian Consumer Law, pursuant to Section 64A, as detailed in Section 17.4 of the Terms of Use.
16.5 Other Regions
For users in jurisdictions not expressly covered above, nothing in this Policy limits any rights you may have under the mandatory consumer protection or data protection laws of your jurisdiction that cannot be excluded or waived by contract.
17. Complaints
If you wish to make a complaint about how we process your personal data, please submit your complaint via email at [email protected]. We will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority or follow the dispute resolution process provided in the Terms of Use.
18. Language
This Privacy Policy may be prepared in multiple languages. In the event of any inconsistency or different interpretation among any language version, the English language shall always prevail.
19. Contact Us
The Platform is operated by APTECH CREATIVE PTE. LTD., registered in Singapore. If you have any questions about this Policy, please contact us using the following details:
| Registered Address | 91 Bencoolen Street, #12-03, Sunshine Plaza, Singapore 189652 |
| Legal / IP Notices | [email protected] |
| Data Protection Officer (DPO) | [email protected] |
| Customer Support | [email protected] |
Last Updated: March 16, 2026