Privacy Policy

Effective Date: 【August 01, 2026】

This Privacy Policy applies to the mini 【dramatub】launched on TikTok (hereinafter referred to as the "Mini Program"). It clearly defines the rules for the collection, use, storage, transmission, sharing and protection of your personal information when we provide you with services including but not limited to mini drama browsing, playback, collection, liking, commenting, personalized content recommendation and interactive sharing.

We strictly comply with the Personal Information Protection Law of the People's Republic of China, Cybersecurity Law of the People's Republic of China, Data Security Law of the People's Republic of China, TikTok developer compliance specifications and cross-border data transmission regulatory requirements, and process users' personal information in accordance with the principles of legality, legitimacy, necessity and minimization. By accessing and using this Mini Program, you confirm that you have fully read, understood and agreed to all terms of this Privacy Policy. If you do not agree with any term herein, please stop using all services of this Mini Program immediately.

This Policy serves as an independent compliance privacy agreement, independent of TikTok’s general platform agreement, and constitutes the exclusive compliance basis for personal information processing of this Mini Program.

1. Scope of Application

This Privacy Policy only applies to all mini drama-related services provided by this Mini Program on the TikTok platform, including but not limited to content display, video playback, interactive operations, content recommendation, user feedback, message notification and compliant data statistics. It does not apply to the main TikTok platform, other third-party mini programs or third-party services.

2. Scope of Collected Information (Minimal Necessity Principle)

We only collect information necessary for the operation of the Mini Program, ensuring service stability, optimizing user experience and conducting compliance risk control, and will never collect irrelevant private information of users. The specific collected information types are as follows:

2.1 Information You Actively Authorize or Submit

To realize account association, interactive functions and personalized services, we collect information that you actively authorize or submit voluntarily, including: your public nickname, avatar and unique user identifier authorized via TikTok; your interactive records generated in the Mini Program including comments, likes, collections and shares; and feedback, suggestions, consultation content and other information you actively submit. We will not proactively request non-essential personal information such as your phone number, ID number or residential address.

2.2 Automatically Collected Device and Behavior Log Information

To ensure smooth drama playback, optimize recommendation algorithms, troubleshoot faults and prevent security risks, we automatically collect minimal necessary device and behavioral data, including but not limited to: device model, operating system, device identifier, network type, IP address, Mini Program access time, drama playback records, viewing duration, browsing tracks, click operations, page stay duration, loading exceptions and fault logs.

2.3 Information Collected by Third-Party SDKs

This Mini Program integrates official compliant TikTok SDKs and necessary statistical and risk control SDKs for content distribution, data statistics and security risk control. The SDKs only collect device information and access logs necessary for service operation. All data processing activities comply with TikTok platform compliance requirements and applicable laws and regulations without unauthorized data collection.

2.4 Information We Do Not Collect

We will not proactively collect sensitive personal information including but not limited to bank card information, payment passwords, biometric information (face recognition, fingerprint), credit investigation information and precise geographic location. We will not compulsorily collect non-essential personal information, nor conduct bundled authorization or silent data collection.

3. Purposes of Personal Information Usage

All collected user information is only used for the following compliant purposes without excessive or abusive use of user data:

1. Basic Service Guarantee: Realize normal loading, playback, caching and interactive functions of mini dramas, ensure stable operation of the Mini Program, fix system faults and optimize playback experience;

2. Personalized Content Recommendation: Recommend high-quality mini dramas accurately based on users’ viewing, browsing and interactive behaviors to improve user experience;

3. Data Statistical Analysis: Conduct anonymized and aggregated statistics on Mini Program operation data and content popularity data to optimize mini drama content quality and iterate product functions;

4. Security Risk Control: Prevent malicious access, fake traffic, inappropriate comments, network attacks and other risks to protect the legitimate rights and interests of the Mini Program, users and the platform;

5. User Service Response: Handle user feedback, complaints and consultations, reply to user inquiries and follow up after-sales requests;

6. Compliance Performance: Comply with TikTok platform operation specifications, national laws and regulations, and legitimate requirements of regulatory and judicial authorities.

If we need to expand the scope of information usage, we will inform users in advance via Mini Program announcements, pop-up windows and other methods and obtain user authorization before implementation.

4. Information Storage, Cross-Border Transmission and Security Protection

4.1 Storage Method and Duration

Users' personal information is stored on compliant servers with encryption, with strict distinction between plaintext data and anonymized data. We adhere to the minimal data retention principle: necessary behavioral data and account-associated information will be retained during your use of the Mini Program. After you stop using the service, we will anonymize and desensitize your data within a compliant and reasonable period, and completely clean up the data upon the expiration of the retention period, only retaining aggregated statistical data for compliance filing.

4.2 Cross-Border Data Transmission Statement

As this Mini Program operates relying on the global TikTok platform, partial data may involve cross-border transmission. We strictly abide by laws, regulations and platform compliance requirements for cross-border data transmission. All cross-border transmitted data is desensitized and encrypted, only used for global service operation and maintenance, content distribution and compliance risk control, and will not be disclosed to protect users' cross-border data security.

4.3 Security Protection Measures

We have established a comprehensive data security management system, technical protection system and permission control mechanism. We adopt technical means including data encryption, interface protection, access permission isolation, security audit and real-time risk monitoring to prevent personal information leakage, loss, tampering and unauthorized access. Meanwhile, we strictly restrict data access and usage permissions of internal staff and cooperative service providers, sign confidentiality agreements and implement full data security responsibilities.

You acknowledge that inherent security risks exist in the Internet and cross-border network environment. We will make every effort to protect your information security. If any information security problem occurs within our controllable scope, we will take remedial measures immediately and inform users and regulatory authorities in accordance with laws and regulations.

5. Information Sharing, Transfer and Public Disclosure

5.1 Information Sharing

We will not share, sell or rent your personal information to any third party without your explicit separate consent. Limited information sharing is only permitted under the following compliant scenarios:

1. Entrusting compliant third-party service providers to provide supporting services such as technical operation and maintenance, data statistics, security risk control and content review for the normal operation of the Mini Program. All partners have signed strict confidentiality agreements with restricted data usage scope and are prohibited from abusing or disclosing user information;

2. Circumstances required by laws, regulations, regulatory authorities or judicial authorities;

3. Necessary circumstances in compliance with laws to safeguard public interests, your legitimate rights and interests or our legitimate rights and interests.

5.2 Information Transfer

In the event of merger, division, acquisition, asset transfer or business restructuring of our enterprise, user data may be transferred along with the business. We will require the transferee to continue to perform privacy protection obligations and protect users' data rights and interests. We will publicly notify users in advance if personal information processing rules are changed.

5.3 Public Disclosure

We will not publicly disclose any of your personal information except for cases of your active public disclosure, authorized disclosure or mandatory disclosure required by laws and regulations.

6. Users' Legal Rights

In accordance with applicable laws and regulations, you enjoy the following personal information rights, which can be exercised through Mini Program functions or official contact channels at any time:

1. Right to Know and Access: You have the right to know the rules of our collection, use and storage of your personal information, and can view your interactive and viewing records and other personal data in the Mini Program personal center;

2. Right to Rectification: You can modify and correct editable personal display information in the Mini Program at any time;

3. Right to Deletion and Clearing: You can independently clear viewing records, collections and interactive data, or contact us to apply for deletion of your personal data;

4. Right to Withdraw Authorization: You can withdraw your authorization for Mini Program information collection at any time. After permission closure, we will stop collecting and using corresponding information, which will not affect legitimate data processing behaviors previously conducted based on your authorization;

5. Right to Complaint and Report: If you believe our data processing behaviors infringe your legitimate rights and interests, you can file complaints and feedback through official channels, and we will verify and reply promptly.

7. Minor Privacy Protection

We attach great importance to the privacy and rights protection of minors. If you are under the age of 18, you shall use this Mini Program service under the knowledge, consent and guidance of your legal guardian. We will not proactively collect sensitive personal information of minors. If guardians find that minors have submitted personal information or used the service without authorization, please contact us in a timely manner, and we will delete relevant data and terminate the corresponding service immediately.

8. Policy Update and Publicity Rules

We may optimize and revise this Privacy Policy appropriately based on business iteration, updates of TikTok platform compliance rules and revision of laws and regulations. The updated policy will be publicly displayed through prominent methods such as Mini Program pop-up windows and page announcements and take effect immediately upon publicity. Your continued use of the Mini Program service after policy updates shall be deemed as your recognition and acceptance of the latest policy terms.

9. Disclaimer

We shall not be liable for personal information risks caused by the following uncontrollable and non-fault situations on our part:

1. Information leakage risks caused by users' improper operation, improper account custody or active information disclosure;

2. Data risks caused by external factors such as network failures, hacker attacks, virus intrusions and force majeure events;

3. System failures of the TikTok platform, faults of third-party platforms and other exemption circumstances stipulated by laws and regulations.

10. Contact Us

If you have any questions, objections, personal information rights applications or complaints regarding this Privacy Policy, please contact us through the following official channels:

Contact Email: 【postmaster@dramatub.com】

Operating Entity: 【Shiri Network Technology Co., Ltd.】