WeComics Privacy Policy

Last Updated:[Feb 15] 2020

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Here is a summary of the information contained in this privacy policy. This summary is to help you navigate the privacy policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.

What information do we need to provide the App?

If you register an account to use the App then we will need some information from you to set this up. We will also process some information when you use the App and when you buy items (e.g., to ensure you get the purchased content). If you choose to set up your App profile using a social media account, we also collect information from that social media account. If you need to get in touch with us then we will also retain some information so that we can get back in touch with you and address any concerns.More Information.

How will we use your information?

We use your information to provide the many functions and services that comprise the App. We also use your information to manage your account and to improve the App. We do not share your information with any third parties, except where we need to in order to provide the App (e.g., use cloud services providers to back up your data; using our affiliates around the world to help us to deliver the App) or we are instructed to by a court, authority or compelled by law.More Information.

Who do we share your information with?

We use some third parties to help us deliver the best possible experience (e.g., cloud services to back up your data). When we use a third party, we only do this to process or store your information for the purposes described in this privacy policy. We also have affiliates around the world who help us deliver the App and we may be required by a court or legal obligation to disclose certain information in some circumstances. More Information.

Where do we process your information?

Our servers are located in the United States. Our support, engineering and other teams are located in our offices around the world (including the United States and Hong Kong).More Information.

How long do we keep hold of your information?

We generally retain your information for the App for the period during which you maintain an account. We dWe generally retain your information for the period during which you maintain an account for this App after which time your data is deleted (as further described in this privacy policy), unless otherwise required by applicable laws. More Information.

How can I exercise my rights over my information?

Depending on where you live, you may have certain rights with respect to your information, such as rights of access, to receive a copy of your data, or to delete your data or restrict or object to our processing of your data.More Information.

How to get in touch with us

If you have any questions about anything in this policy, or want to exercise any rights you may have, please contact us here.

How will we notify you of changes?

If there are any significant changes to this privacy policy, we will update the policy here. More Information.

Contact Information

Data Controller: Rich Lord Investments Limited. Email: support@wecomics.com



EU Representative: Tencent International Service Europe B.V. Email: eudataprotection@tencent.com

Welcome to WeComics!

This privacy policy explains the when, how and why when it comes to processing of your personal information in connection with the WeComics application (the “App”) and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

If you do not agree to the processing of your personal information in the way this privacy policy describes, please do not provide your information when requested and stop using the App. By using the App you are accepting our rules regarding your personal information as described in this privacy policy.

This App has been developed by the Tencent group (“we”, “us”, “our”). For the purpose of data protection laws, the data controller of your personal information in relation to the App is Rich Lord Investments Limited, which is a Hong Kong-based company within the Tencent group. The registered address of Rich Lord Investments Limited is 29/F, Three Pacific Place, No.1 Queen’s road East, Wanchai, Hong Kong. Our representative in the EU for the purpose of EU data protection laws is Tencent International Service Europe B.V., a company registered in the Netherlands, with the registered address at 26.04 on the 26th floor of Amstelplein 54, 1096 BC Amsterdam, the Netherlands and can be contacted at eudataprotection@tencent.com. Our data protection officer can be contacted at dpo@wecomics.com.

Please reach out to us if you have any questions or concerns regarding the processing of your personal information: you can contact us anytime at support@wecomics.com.

The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled “How we use your personal information” below.

The following is a high level summary of the types of personal information we use:

1. Information you provide to us (either directly or through a third party). 

When you register for the App, we collect information to create an account for you on the App, including email address, avatar, nickname, date of birth, gender, age and hobbies. If you link your account on the App to your social media profile on third party websites including Facebook, Twitter and Google, we also collect third party log-in authorization information where required by you (and as authorized by the third party website).

2. Information about you generated as part of the App (and its in-App services)

We automatically collect certain data from you when you use the App, including your IP address and other device information (the model or brand of the device you use to access the App, the system version, system language, resolution, network status and your telephone carrier). We also collect and store your data as follows:

if you conduct any transactions within the App, we receive information to facilitate your transaction and store your information to maintain transaction records (including your country/region code, currency code, order ID, IP address, price and item information, time of purchase);

when you are using the App we collect your device information, the information you use to register your account with, behavioural information when you use our app and login authorization information we obtain from third party sites such as Facebook/Twitter/Google etc.; and

if you contact our support team, we collect your nickname, your device information and information generated in the course of using the App, such as your App access records.

3.Information you generate and display in the course of using the App.

We collect information that you generate in the course of using the App. The information we collect includes your downloads, likes, comments and purchases. The App log information that we collect includes account ID, records when you log in and log out of your account, and your access to the content of the App.

Children

The App is not intended for or targeted towards users under the age of 13 years. In the case of individuals located in the countries specified below, the specified age applies to you.

Country/region Minimum age
Australia 18
Bangladesh 18
Brazil 18
European Economic Area(all EU countries, Iceland, Liechtenstein and Norway) 16
India 18
Malaysia 18
Switzerland 16
Indonesia 21

In the case of users located in the European Economic Area and Switzerland, persons under the age of 16 may use the App if parental/guardian consent is obtained prior to using the App.

We do not knowingly collect personal information from children under this age for any purpose. If you believe that we have personal information of a child under this age, please contact us at support@wecomics.com and we will delete such information.

How We Use Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why. For users who live in the European Economic Area (“EEA”) or Brazil, it also identifies the legal basis under which we process your data.

Personal Information Use Legal Basis (only relevant if you are located in the EEA)
Information you provide to us (either directly or through a third party). 
Account information: email address, avatar, nickname, date of birth, gender, age and hobbies. We use this information to create an account on the App for you. Necessary to perform our contract with you to provide the App.
Third party log-in information: Information you have provided to third party websites such as Facebook, Twitter and Google. Upon your request, we use this information to link your App account to your social media profile on the third-party website to enable you to log-in to the App through the third-party website. Necessary to perform our contract with you to provide the App.
Information generated as part of the App (and its in-App services)
Device Information: IP address, the model or brand of the device used to access the App, the system version, system language, resolution, network status and telephone carrier. We use your device information to improve our services, including the functionality of the App on different devices. Necessary to perform our contract with you to provide the App.
User behavioural and App Log Information: records of log in and log out, downloads, likes, comments and purchases.

We use this information to:

maintain a record of log-in and actions of your account;

improve our services, including the functionality of the App;and

for troubleshooting purposes.

Necessary to perform our contract with you to provide the App.
In-App Purchase Information: country/region code, currency code, order ID, IP address, price and item information.

We receive this information when you make a purchase while using the App. Of this information, we store the time, order ID, IP address, price and item information of in-App purchases.

We use this information to facilitate your payment and to maintain a record of your purchase history.

Necessary to perform our contract with you to provide the App.
Customer support ticket ID and user communications with support: Information provided by you when contacting our customer support team using the relevant support email.

We use this information to:

improve our services;

provide troubleshooting, such as addressing and remediating technical issues and bugs.

Necessary to perform our contract with you to provide the App.

We may collect other personal information from you from time to time for specific reasons (such as a promotion in your country). When this happens, we will make you aware of the fact that the information is being collected and provide more information on any specific changes to the way we process that personal information that might differ to this privacy policy prior to collecting or processing that personal information. In some cases, that information may be processed on the basis of your consent – and if that is the case, we will provide you with further information on how we process that information and your rights.

How We Store and Share Your Personal Information

The Tencent group operates around the world. Pursuant to our contract with you to provide you with the App, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this privacy policy. Our servers are located in the United States.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

Third parties including providers of cloud services that process information identified in this policy on their servers for the purpose of providing the App. All such third party service providers are prohibited from using your personal information for any purpose other than providing us with their services.

Social media platforms and networks, such as Facebook and Twitter that offer functionalities, plugins, widgets, or tools in connection with our website or mobile application (e.g., to log into an account, or to share content with your friends and followers on social media). If you choose to use these functionalities, plugins, widgets, or tools, certain information may be shared with or collected by those social media companies—for more information about what information is shared or collected, and how it is used, see the applicable social media company’s privacy policy.

Companies within the Tencent corporate group who process your personal information in order to operate the App. All related group companies may only use your personal information in accordance with this privacy policy.

Regulators and judicial authorities and law enforcement agencies. There are circumstances in which we are legally required to disclose information, including to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users.

A third party that acquires all or substantially all of us or our business. If we sell or buy any business, undergo a merger, enter into a partnership, or sell some or all of our assets we may disclose your information to the prospective buyer of such business. Under these circumstances, we will always require the prospective buyer to comply with this privacy policy.

Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our services; therefore we do not assume any responsibility for any transmission of your information which you do at your own risk.

Data Retention
Personal Information Retention Policy
Account information* Stored for the lifetime of your use of the App (i.e. until account deletion in accordance with your request) and then for 30 days.
Third party log-in information* Stored for the lifetime of your use of the App (i.e. until account deletion in accordance with your request) and then for 30 days.
Device Information* Stored for the lifetime of your use of the App (i.e. until account deletion in accordance with your request) and then for 30 days.
User behavioural and App Log Information* Stored for the lifetime of your use of the App (i.e. until account deletion in accordance with your request) and then for 30 days.
In-App Purchase Information* Stored for the lifetime of your use of the App (i.e. until account deletion in accordance with your request) and then for 30 days.
Customer Support Ticket ID & User Communications with Support* Stored for the lifetime of your use of the App (i.e. until account deletion in accordance with your request) and then for 30 days.

*Full description of data is set out in the section “How We Use Your Personal Information” above.

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

Some countries’ laws grant specific rights to users of the App, which are set out in this section.

This section entitled “Your Rights” applies to users that are located in the European Economic Area.

The sub-sections entitled “Access”, “Correction”, and “Erasure” also apply to users that are located in Canada and India.

The sub-sections entitled “Access”, “Portability”, “Correction”, and “Erasure” and “Objections” also apply to users that are located in Brazil.

You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please email us at dpo@wecomics.com.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your App account. If you believe we hold any other personal information about you, please contact us at dpo@wecomics.com.

Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you, as described above in the section “How We Use Your Personal Information”. You have the right to receive this personal information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer it to another party, with certain exceptions. We will provide further information to you about this if you make such a request.

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your App account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo@wecomics.com.

Erasure

If there is any personal information you believe we process that you would like us to erase, please contact us at dpo@wecomics.com.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the App and there are grounds for erasure, we will use reasonable steps to try to tell others who are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at dpo@wecomics.com.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at dpo@wecomics.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend App access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.

Contact & Complaints

We welcome questions, comments and requests regarding this privacy policy. Please address them to dpo@wecomics.com.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at dpo@wecomics.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you consider we have infringed data protection laws.

Changes

If we make any material changes to this privacy policy, we will post the updated policy here and notify our users within the App. Please check this page frequently to see if there are any updates or changes to this privacy policy.

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some countries’ laws contain additional terms for users of the App, which are set out in this section.

If you are a user located in one of the countries below, the terms set out below under the name of your country apply to you.

Australia

Children

If you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the App.

Transacting Anonymously

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the App. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the App, including social media integration and in-App purchases.

Your rights

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone +61 1300 363 992 or email enquiries@oaic.gov.au).

Data transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.

Bangladesh

Agreement

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORIZE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL DATA, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

BY CLICKING “ACCEPT”, YOU CONSENT TO THE CROSS-BORDER TRANSFER OF YOUR INFORMATION TO ANY COUNTRY WHERE WE HAVE DATABASES OR AFFILIATES AND, IN PARTICULAR, TO THE UNITED STATES.

Age Restriction

In order to use the App, you represent that you are at least 18 years old and, therefore, legally capable of entering into binding contracts.

No spam emails

We are committed not send any spam email or undesired email to you without your permission for advertising or marketing purposes.

Brazil

In order to use the App, you represent that you are at least 18 years old and, therefore, legally capable of entering into binding contracts.

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORIZE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL DATA, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

In addition to the rights set out in “Your Rights” Section of this policy, you will have right to information on the public and private entities with which we have shared your personal data.

California

The California Consumer Privacy Act (“CCPA”) contains additional terms for California residents using the Services, which are set out in this section.

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:

Identifiers, including your email address, avatar, nickname, date of birth, IP address, and nickname. We collect this information from you and your device.

Internet or other electronic network activity information, including third-party log-in information, the model or brand of the device used to access the App, as well as the system version, system language, resolution, network status and telephone carrier, records of log in and log out, network status, ROM, and CPU and memory size. We collect this information from you and your device.

Commercial information, including information about your transaction, such as what was purchased, the time of purchase, the currency and country code associated with the purchase, the price of the purchase, and whether payment for the order in question is completed. When you pay for our products, you will provide our payment processors your payment card information, and we will obtain your other commercial information directly from you.

Other information described in subdivision (e) of Section 1798.80, including your gender, age, and hobbies. We collect this information directly from you.

We collect your personal information for the following purposes:

To operate and improve WeComics;

For security and verification purposes, including to prevent and detect fraudulent activity; and

To address and remediate technical issues and bugs.

For additional information about what each type of personal information is used for, see this chart [Note to product: please link in the main portion of the Privacy Policy].

We disclose personal information to the following types of entities:

Our affiliate companies within our corporate group who process your personal information in order to operate the Services

Other companies that provide services on our behalf who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing the services to us

Other users of WeComics with respect to personal information you transmit through WeComics

Regulators and judicial authorities and law enforcement agencies

Entities that acquire all or substantially all of our business

In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA.

Rights under the CCPA

If you are a California resident and the CCPA does not recognize an exemption that applies to you or your personal information, you have the right to:

Request we disclose to you free of charge the following information covering the 12 months preceding your request:

the categories of personal information about you that we collected;

the categories of sources from which the personal information was collected;

the purpose for collecting personal information about you;

the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and

the specific pieces of personal information we collected about you;

Request we delete personal information we collected from you, unless CCPA recognizes an exception; and

Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.

We aim to fulfill all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may exercise your rights, if any, to other data by contacting us at dpo@wecomics.com or completing this form [Note to product: link to webform].

India

SHARING OF YOUR PERSONAL INFORMATION

Where we permit any third parties to collect and use your Personal Information, we shall take reasonable measures to ensure that the third parties do not further disclose the Personal Information.

AGE RESTRICTIONS

Children under the age of 18 are not allowed to execute online contracts with us or sign up for our services. Parental consent is required for children under the age of 18 years to avail our services.

Indonesia

Consent

By accepting and consenting to this privacy policy, you agree that we may collect, use and share your Information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our services and we have the right to not provide you with access to our services.

Accuracy of Information

You are responsible to make sure that any personal information which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you already secure all necessary consent before providing us with other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claim whatsoever from any party as a result of absence of such consent.

Parental and Guardian Consent

If you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to register an account on and use the App.

Data Subject Rights

You have the right to access, update, correct and request for erasure of personal information in our App from time to time in accordance with applicable data privacy laws and regulations in Indonesia.

Data Breach

In the event we fail to maintain the confidentiality of your personal information in the App, we will notify you through the contact information provided by you or via the App, to the extent required by local laws and regulations, at the latest 14 days since we acknowledge the breach of confidentiality.

Data Retention

Notwithstanding the provision on the erasure of personal information, to the extent required by local laws and regulations, we will retain your personal information, at the latest for 5 years.

Notification to Amendment of this Privacy Policy

In the event we amend this policy, we will provide a notification to you regarding the effective date of the changes at the latest 14 (fourteen) days prior the effective date, through (i) a notice to be posted on the landing page of our website, pop-up notification, or the splash screen of our mobile App or (ii) the contact information you provided to us. If you fail to explicitly express your objection to the amended policy within the above advance notification period, you will be considered as accepting the changes, therefore you will be considered to have agreed to the new policy.” However, you may stop using or accessing our App by unsubscribing at any time, if you cease to agree with the changed policy.

Malaysia

Language of this Privacy Policy

In the event of any discrepancy or inconsistency between the English version and Malay version, the English version shall prevail.

Parental and Guardian Consent

If you are under the age of 18, please do not use the App.

In the event you are agreeing to this Privacy Policy in order for a minor to access and use the App, you hereby consent to the provision of personal information of the minor to be processed in accordance with this Privacy Policy and you personally accept and agree to be bound by the terms in this Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor's compliance with this Privacy Policy.

Rights of Data Subjects

Right of access: You have the right to request access to and obtain a copy of information of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for access of your personal information in the amounts as permitted under law.

When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However this may affect our provision of the App to you.

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

Our data protection officer, responsible for the management and safety of your personal information

Telephone: [+86-0755-86013388-72004]

Email: dpo@wecomics.com.

New Zealand

Consent

You are under no obligation to provide us with any personal information that we request. However, if you choose to withhold personal information requested by us [we may not be able to provide you with certain services or functionality].

Your rights

You have the right under the Privacy Act 1993 to ask for a copy of any personal information we hold about you, and to ask for it to be corrected if you think it is wrong. If you would like to ask for a copy of your information, or to have it corrected, please contact us here. We rely on you to update us if your personal information changes.

Singapore

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to the United States.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted at dpo@wecomics.com.