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Narae is a web-novel app accessible via a browser through the website www.narae.eu and through a mobile app for Android (hyperlink) or iOs (hyperlink). Narae is operated by Bookrepublic WebNovels S.R.L, a company registered in Milan under company number 13267150962 with a registered office located in Via Degli Olivetani 12 and reachable via email here: customer@narae.eu
This Policy explains how we at BookRepublic Webnovels protect and handle any personal information you provide to us when using Narae via our app or website or Narae-related services, including our social media pages/accounts, email and any other form of contact happening between you and us. It also covers any personal information we receive from third parties and provides you with an overview of your rights.
This policy is provided pursuant to art. 13 of Regulation (EU) 2016/679 ("GDPR"), and the Italian Legislative Decree no. 196 of 2003 as amended by Legislative Decree no. 101 of 10 August 2018 ("Privacy Code") and other applicable rules on the protection of personal data.
For the purposes of this policy, the Data Controller is: BookRepublic Webnovels SRL located in via degli Olivetani 12 20123 Milano, Italy, reachable also via email at this address privacy@narae.eu
sWe collect the following kind of information.
a. Data that you have given us directly
This type of data includes the data required to create an account to Narae to communicate with us through our customer service, or to subscribe to our newsletter, promotions or offers and may include: name, email address, your Region and username.
b. Data of technical nature retrieved from your device
This type of data is collected any time you interact with Narae via app or website, when you create an account and when you use our services as a non-registered user and may include:
c. Information about your purchases made on Narae
If you purchase coins on Narae we collect information about your purchase such as the amount of coins purchased, and the usage of those coins.
d. Other Data from Social media or external services that might identify you
This is personal information that we collect from social networks, such as TikTok, Instagram etc. We collect and analyze this information whenever, for example, you publish something on our official pages hosted on these social networks or when you post something about us (for example, you remix a TikTok video or make us participate in one of your posts through any tag).
If you sign-up and log-in on Narae using one of your third parties account (for example, you sign-up on Narae by using your Google Account) you are granting permission to such company to share your user information with us. This will include your name and email address plus any other information you have permitted them to share with third parties. If you remove our website from your Google account, we will no longer have access to this information.
e. App notification/Browser notification
In addition to all the aforementioned information, when you click to a push notification from our app or our website, we may also collect the topics of the notification (such as new releases, new promotions, reminder and so on) you have clicked on or interacted with, and perform marketing analysis
f. Newsletter
We might ask you to subscribe to our newsletter to receive information over the webnovel of your choice such as new episodes releases. When subscribing to our newsletter we will ask you to enter your email address in the registration form or when you sign-in. We will use such data solely to provide you with our newsletter. When you subscribe to our newsletter, your IP address and the date and time of the registration will also be automatically stored on our servers (or the servers of our service providers). The collection of this data is necessary in order to understand the (possible) misuse of the email address of a user at a later date, and it therefore serves us to prove that our registration process is in line with legal requirements.
g. Cookies
We might ask your consent to install cookies on your device when you download our app or visit our website to remember your identity, keep your session open and remember your preferred setting. We also use analytics cookies to gather information about what content, episodes, actions and initiatives of our app are popular to help us keep our Content relevant and up to date. For further information, please see our cookie policy (hyperlink)
We rely on the following legal bases to process your personal data:
We only disclose your personal data to third parties when it is absolutely necessary for the purpose of providing Narae to you. We may pass your information to our processors – companies that we use to provide services such as web hosting and newsletter delivery. These processors can only use your information in accordance with our instructions and for no other purpose. Legal basis for processing this data is Contract or consent (if requested) or legitimate interests.
We use the following service providers:
Newsletter: we use an external provider (SendGrid by Twilio) to send our newsletter to all the users who chose to subscribe. You can check their privacy terms here (https://www.twilio.com/en-us/legal/privacy).
Analytics: We use an integration of Firebase and Google Analytics.
Firebase is a set of backend cloud computing services and application development platforms provided by Alphabet Inc. It hosts databases, services, authentication, and integration for a variety of applications, including Android and iOS. We use it for Narae’s app and we integrate it with Google Analytics. Here is their privacy policy (hyperlink: https://firebase.google.com/terms/data-processing-terms)
Google Analytics is a web analytics service provided by Alphabet Inc., (“Google”). We use Google Analytics in Narae to collect usage and behavior data for the app and website.
Our setting logs two primary types of information: What is happening in the app such as user actions, system events or errors; and User properties, that are attributes defined to describe segments of our user base, such as language preference or geographic location.
The information collected by Google Analytics including the anonymized IP address will be transmitted to and stored by Alphabet on servers in the United States.
According to Google only in exceptional cases the full IP address may be transmitted directly to a Google server in the USA and encrypted there. Any user-identifiers (e.g. Cookie-ID) stored by Google Analytics will automatically be deleted from Google’s servers after 14 months. For further information please refer to Googles Analytics security and privacy principles: https://support.google.com/analytics/answer/6004245?hl=en.
Opt-Out: You can prevent the processing of your data by Google Analytics by installing the Google Analytics opt-out browser add-on available under https://tools.google.com/dlpage/gaoptout. The browser add-on is available for most browsers.
Legal basis for processing this data: Contract or consent (if requested) or legitimate interests
Cloud servers: We use Amazon AWS to distribute our services to our users. All the servers are located in the EEA. For further information (hyperlink: https://aws.amazon.com/it/products/?aws-products-all.sort-by=item.additionalFields.productNameLowercase&aws-products-all.sort-order=asc&awsf.re%3AInvent=*all&awsf.Free%20Tier%20Type=*all&awsf.tech-category=*all)
Legal basis for processing this data: Contract or consent (if requested) or legitimate interests
Social media and social plugins: we will use the advertising capabilities of Facebook and Tiktok platforms any time you interact with our content hosted on them, or through any of their social plugins through Narae. For further information:
Meta adv: https://www.facebook.com/privacy/policy/
TikTok adv: https://ads.tiktok.com/i18n/official/policy/privacy
Legal basis for processing this data: Contract or consent (if requested) or legitimate interests
Should we engage in a joint controller processing of your data with other companies for specific operations we will inform you and request consent where needed. The legal basis for processing this data is to protect our legitimate interests.
We do not share or sell your data to third parties. However, if our company organization will change in the future, we may transfer, sell or assign any of the information described in this Policy to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or re-organization of our business. The legal basis for processing this data is to protect our legitimate interests
We store your data for no longer than necessary in relation to the purpose under which such data was collected. This is determined on a case by case basis and depends on things such as the nature of the data provided, why it was collected, the legal basis we rely upon to process the data, and our relevant legal or operation retention requirements.
For example, if you request to delete your account because you don’t want to use Narae anymore, while we will delete your account we still have to retain some data for fraud prevention purposes and financial auditing.
Technical data tied to your account are retained until your account is active. The technical data of non-registered users are retained until the users terminate their active session on their browser or uninstall the app. Transaction data is not automatically coupled with a non-registered user identity since we do not identify directly such users.
All the data are stored in servers based in the European Economic Area (EEA) and are not transferred to third countries. Technical data (data not directly matched with other data in our possess that could identify you univocally), such as Google Analytics identifiers might be stored outside the EEA.
When transferring your personal data outside the EEA we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data and, where appropriate, use the EU Commission approved model clauses with these organizations to ensure appropriate safeguards are in place. We will take every reasonable step to ensure the security of your personal data in accordance with the GDPR and any applicable data protection laws.
Personal information is maintained on our servers or those of our contractors, and is accessible by authorized employees, representatives, and agents as necessary for the purposes described in this privacy policy.
We use reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal information.
To exercise your rights under the GDPR, please contact us at privacy@narae.eu indicating the type of right you would like to exercise and that you are making the request under the GDPR. In case of requests for deletion, please note there may be circumstances where we are legally entitled to retain certain data. We may seek to verify the identity of the person submitting the request.
The GDPR grants you the access of the following rights:
Access and portability: if you wish to exercise the right to access your data or download a copy of your data you can write an email to: privacy@narae.eu
Deletion: you may ask us to delete your data. If you are a registered user you can do so personally from the app or your account settings or by writing us to: customer@narae.eu Please remember that there might be circumstances where we are legally obliged to retain your data such as in the case of purchases
Rectification: If you are a registered user you can update your data personally or by contacting our customer service
Restriction or suppression: you may ask us for restriction or suppression of your data by contacting us.
Revoke your consent to newsletters and notifications: you can unsubscribe from our email by clicking unsubscribe ad the bottom of each email; you can revoke the permission to receive push notifications from your device or your browser settings
Objection to automated profiling: If you wish to opt-out of having your personal information profiled for personalization purposes, you can adjust your account settings or contact us directly.
Objection to legitimate interests: If you wish to object to our processing of your data where we are pursuing our legitimate interests or those of a third party, please contact us at the contact details provided below stating the nature of and reasons for such objection.
Complain: You also have the right to lodge a complaint about us with the local supervisory authority (hyperlink: https://www.garanteprivacy.it/home/docweb/-/docweb-display/docweb/4535524)
Where the processing is based on your consent, you also have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
For any inquiries please contact us at: privacy@narae.eu or BookRepublic WebNovels SRL Via Degli Olivetani 12 20123 Milano, Italy
We may change this privacy policy at any time with effect for the future. The then current version of this policy will be made available on the app and on the website on this page, so please make sure to always check our most current version. If changes are significant, we may choose to notify you by email or to clearly indicate in the app that the policy has been updated.
This policy was last time updated: INSERT DATE
