Last Updated: May 24, 2018

This Privacy Policy (“Policy”) describes the manner in which ZHIKU (HONG KONG) TECHNOLOGY LIMITED, operating the HoneyNovel service (“HoneyNovel”, “we,” or “us”), as well as all related websites, networks, applications, and other services provided by us and on which a link to this Policy is displayed (collectively, together with the Site, our “Service”) collect, use, disclose and otherwise process Personal Information. “Personal Information” means any information relating to an identified or identifiable individual. This Policy, which is incorporated into and is subject to the HoneyNovel Terms of Service, describes the information that we gather from you on the Service, how we use and disclose such information, and the steps we take to protect such information.

1. Personal Information We Collect:

We may collect Personal Information about you from various sources described below. Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Service if that information is necessary to provide you with it or if we are legally required to collect it.

• User-provided InformationWhen you use the Service, we ask you to provide certain Personal Information about you, including your name, gender, email address, mailing address, phone number, credit card or other billing information, your date of birth, geographic area, or preferences and we may link this information with other information about you. For example, we may ask you to provide us with Personal Information when you register for an account, use the Service, or make a purchase on the Service.We may also collect any other Personal Information that you choose to provide to us. For example, if you decide to contact us with a request, we will process the content of your message, the date and time of your message, our response and any other Personal Information you provide in that context. If you contact us to apply for a job with HoneyNovel, we will process your job application, including your curriculum vitae and other Personal Information you submit to us in that context.
• Automatically Collected Information. When you use the Service, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your device. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Service. We may also automatically record certain information from your device by using various types of technology, including “clear gifs" or “web beacons.” In this context, we may collect certain information about you, such as your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after you use the Service, the pages or other content you view or otherwise interact with on the Service, and the dates and times that you visit, access, or use the Service. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message. This information is gathered from all users, and may be connected with other information about you.

  Please review your web browser “Help" file to learn the proper way to modify your cookie settings. Please note that if you delete, or choose not to accept, cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential. We may use third party cookies on our Service as well. For instance, we use Google Analytics to collect and process certain analytics data. Google provides some additional privacy options described at www.google.com/policies/privacy/partners/ regarding Google Analytics cookies.

  HoneyNovel does not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who visit our Site or who use our Service.

• Location Information.We may obtain information about your physical location, such as by use of GPS and other geolocation features in your device, or by inference from other information we collect (for example, your IP address indicates the general geographic region from which you are connecting to the Internet).
• Third Party Web Beacons and Third Party Buttons.We may display third-party content on the Service, including third-party advertising. Third-party content may use cookies, web beacons, or other mechanisms for obtaining data in connection with your viewing of the third party content on the Service. Additionally, we may implement third party buttons (such as Facebook “like” or “share” buttons) that may function as web beacons even when you do not interact with the button. Information collected through third-party web beacons and buttons is collected directly by these third parties, not by HoneyNovel. Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies.
• Information from Other Sources.We may obtain information from third parties and sources other than the Service, such as our partners and advertisers.
• Publicly accessible sources.We may collect information about you, such as [Google, Facebook, Twitter] from publicly accessible sources, including [username, avatar, location].

2. How We Use the Personal Information We Collect.

We use information we collect on the Service in a variety of ways in providing the Service and operating our business, including the following:

• We use the Personal Information that we collect on the Service to operate, maintain, enhance and provide all features of the Service, to provide services and information that you request, to respond to comments and questions and otherwise to provide support to users, to contact you for administrative purposes such as customer service, and to process and deliver entries and rewards in connection with promotions that may be offered from time to time on the Service.
• We use the Personal Information that we collect on the Service to understand and analyze the usage trends and preferences of our users, to improve the Service, and to develop new products, services, features, and functionality.
• We may use your email address or other Personal Information we collect to send marketing communications, including updates on promotions and events, relating to products and services offered by us and by third parties.
• We may use cookies and automatically collected Personal Information to: (i) personalize our Service, such as remembering information about you so that you will not have to re-enter it during your visit or the next time you visit the Service; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of the Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Service.

If you are located in the European Economic Area, we only process your Personal Information based on a valid legal ground, including: consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you, for example to deliver the Services or respond to your inquiries), our or a third party’s legitimate interests (for example, to personalize our Services and provide you with tailored content, conduct business analytics, and otherwise improve the safety, security, and performance of our Services) or to comply with our legal obligations. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

3. When We Disclose Personal Information.

Except as described in this Policy or otherwise disclosed to you at the time of the collection, we will not disclose information about you that we collect on the Service to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

• Any information that you voluntarily choose to include in a publicly accessible area of the Service will be available to anyone who has access to that content, including other users.
• We work with third party service providers to provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to or process information about you as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.
• We may disclose information about you if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
• We also reserve the right to disclose information about you that we believe, in good faith, is appropriate or necessary to: (i) take precautions against liability; (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity; (iii) investigate and defend ourselves against any third-party claims or allegations; (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available; or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
• Information about our users may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
• We may make certain aggregated, automatically-collected, or otherwise de-identified information available to third parties for various purposes, including: (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Service.

4. Your Rights and Choices

Your Account.You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Service. You may update, correct, or delete your account information and preferences at any time by accessing your account preferences page on the Service. If you wish to access or amend any other Personal Information we hold about you, you may contact us at hotnovelservices@gmail.com. Please note that while any changes you make will be reflected in active user databases within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

Marketing Communications.If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt out from receiving commercial email from us by sending your request to us by email at hotnovelservices@gmail.com or by writing to us at the address given at the end of this policy. We may allow you to view and modify settings relating to the nature and frequency of promotional communications that you receive from us in user account functionality on the Service.

Please be aware that if you opt out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may continue receiving promotional communications from us during that period. Additionally, even after you opt out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.

Automated Collection. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Site. Please note that there is currently no uniform way in which to respond to Do Not Track signals, and at this time we do not respond to such signals.

Other Rights and Choices.

• If you are located in the European Economic Area or Switzerland, you may have the following additional rights: Request access to and receive information about the Personal Information we maintain about you, to update and correct inaccuracies in your Personal Information, to restrict or to object to the processing of your Personal Information, to have the information anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
• Withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.

These rights may be limited in some circumstances by local law requirements. You may exercise these rights by using the “How to Contact Us” section below.

5. Third-Party Services

The Service may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

6. Children’s Privacy

Protecting the privacy of young children is especially important. Our Site is a general audience site not directed to children under the age of 16, and we do not knowingly collect Personal Information from children under the age of 16 without obtaining parental consent. If we learn that Personal Information has been collected on the Services from persons under 16 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this Personal Information. If you are a parent or guardian and discover that your child under 16 years of age has obtained an account on the Services or that we may have collected information from that child through our Services, then you may alert us hotnovelservices@gmail.com and request that we delete that child’s Personal Information from our systems.

7. Data Security and Retention

We use certain physical, managerial, and technical safeguards that are designed to to appropriately protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. Please be aware that no security measures are perfect or impenetrable. We cannot and do not guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

8. International Data Transfers

We may transfer your Personal Information to countries other than the country where you are located, including to Hong Kong. When we transfer Personal Information outside of the European Economic Area, we will comply with applicable EU data protection laws. We may transfer your Personal Information to countries which provide an adequate level of protection under EU law, or we may use contractual protections for the transfer of Personal Information. You may contact us as specified below to obtain a copy of the safeguards we use to transfer Personal Information outside of the European Economic Area.

By providing any information, including personal information, on or to the Service, you consent to such transfer, storage, and processing.

9. Changes and Updates to this Policy

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify this Policy, we will make it available through the Service, and indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the Service for the first time after such material changes are made. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of this Policy.

10 .Your California Privacy Rights

Residents of California have the right to request a disclosure describing what types of personal information we have shared with third parties for their direct marketing purposes, and with whom we have shared it, during the preceding calendar year. You may request a copy of that disclosure by contacting us hotnovelservices@gmail.com.

11. How to Contact Us

ZHIKU (HONG KONG) TECHNOLOGY LIMITED is the entity responsible for the processing of your Personal Information.

Please contact us with any questions or comments about this Policy, information we have collected or otherwise obtained about you, our use and disclosure practices, or your consent choices by email hotnovelservices@gmail.com.

You may also write to us at:

ZHIKU (HONG KONG) TECHNOLOGY LIMITED

RM 4 16/F HO KING COMM CTR 2-16 FAYUEN ST MONGKOK KL