Privacy Policy

Last updated: August 7, 2026

1. Introduction

1.1 Thank you for using the “ToonBox” platform and related services (collectively, “ToonBox” or the “Services”) provided by Spark Deep Intelligence Technology Co., Limited (“we,” “us,” or the “Company”). When you use ToonBox, we may collect and process your personal data in accordance with this Policy and applicable law. This Policy is intended to help you understand how we collect, use, store, share, transfer, and protect your personal data, as well as the rights and choices you have in relation to such personal data. We value your privacy and will protect your personal data and privacy in accordance with applicable law.

1.2 This ToonBox User Privacy Agreement (the “Policy”) forms part of and is governed by the Platform User Agreement and applies to ToonBox and its related services and content. This Policy describes our collection, use, disclosure, and other processing, in accordance with applicable laws and regulations, of the personal data of users who have entered into a contract with us and whose personal data is in our possession or under our control.

1.3 Please carefully read and understand the entire ToonBox User Privacy Agreement before using ToonBox. We will process your personal data in accordance with applicable law and on an appropriate legal basis, such as performing a contract, complying with a legal obligation, protecting legitimate interests, or obtaining your consent. For processing activities that legally require consent, we will provide you with the necessary information and obtain your express consent before processing. Where sensitive personal data, personalized advertising, cross-border transfers, or minors’ data is involved, we will also comply with additional notice, separate consent, or other compliance obligations under applicable law. If you do not agree to the provisions of this Policy relating to essential Services, please do not register for, log in to, access, or use ToonBox. For non-essential data processing, you may choose whether to consent or withdraw your consent in accordance with this Policy and the settings provided in the product.

1.4 Age Restrictions: Children under the age of 13 may not register for, log in to, access, or use ToonBox or its related Services. Minors who are at least 13 but under 18 years of age must, where required by applicable law, obtain the prior consent of a parent or legal guardian and use ToonBox and its related Services under their supervision and guidance. If the age of digital consent under the laws of your location is higher than 13, the higher age threshold prescribed by local law will apply. To the extent permitted by applicable law, we may take reasonable age-verification measures and, where necessary, require verifiable parental or guardian consent. For more information on age restrictions and requirements for protecting minors’ data, please refer to Section 8 of this Policy.

1.5 If you have any questions about this ToonBox User Privacy Agreement or any issues concerning personal data and data protection, you may contact us using the contact details set out in this Policy.

1.6 This ToonBox User Privacy Agreement informs you of the following:

(1) Customer Information We Collect

(2) Purposes for Which We Collect and Use Personal Data

(3) How We Share and Disclose Your Personal Data

(4) Personalized Advertising Services

(5) Cookies and Similar Technologies

(6) How We Store and Protect Your Personal Data

(7) Your Rights and Choices

(8) Age Restrictions

(9) Other Provisions

(10) Contact and Complaints

2. Customer Information We Collect

We collect data that you voluntarily provide when using the Services, as well as data generated when you use ToonBox features or receive the Services that we collect through automated or other means, including but not limited to:

2.1 Account Data:

2.1.1 We collect personal data that you provide when registering, logging in, or using the Services, including your mobile phone number or email address, gender, nickname, profile picture, and other data. You must ensure the accuracy of the data you provide. We collect this data to provide account registration and login services, complete your online identity profile, and safeguard the security of your account.

2.1.2 If you choose to log in to ToonBox through an account on a third-party platform (for example, Facebook, Google, or Apple ID), with your consent, we will obtain the public account data registered by you on that third-party platform (including your name, profile picture, mobile phone number, email address, and other data authorized by you) and use it to link your third-party account to your ToonBox account, enabling you to log in directly to ToonBox and use the related Services.

2.2 Camera or Photo Library Permission: When you set or change your profile picture or use other related features, we need to obtain permission to access your device’s camera or photo library and obtain photos, images, and other data. If you refuse to grant such device permissions, you will be unable to use these features, but this will not affect your normal use of other features of ToonBox and/or the Services.

2.3 Calendar Permission: When you use appointment reminders or check-in features (if available), we will request calendar permission. If you refuse to grant permission, you will be unable to use this feature, but this will not affect your normal use of other ToonBox features.

2.4 Clipboard Permission: With your express authorization, we may access content in your device’s clipboard (such as text, images, or videos). Such access is limited to actions that you actively initiate, such as pasting clipboard content into the Platform. We will not read, store, or upload clipboard content without your authorization or an action initiated by you, nor will we use such content for any purpose unrelated to your request.

2.5 Device Data and Log Data:

2.5.1 To ensure the secure operation, operational quality, and efficiency of the software Services, we collect your device model, operating system version, device identifiers [on Android, such as IMEI, Android ID, and GAID; on iOS, such as IDFV and IDFA; different identifiers may vary in validity period, whether they can be reset by the user, and how they are obtained], network adapter address (device MAC address), IP address, network access method, type, status, network quality data, and operation, usage, and Service logs.

2.5.2 To provide you with better product Services and ensure effective playback and use when you use the product, we may obtain system data such as your device’s screen status and system volume level.

2.5.3 We also collect data relating to application error reports and performance monitoring, including but not limited to account registration/login time, language, access date and time, application source, application version number, data concerning running processes, stack trace data at the time of a system crash, crash reports, and abnormal process logs. Collecting this data helps us better understand the condition of your device, improve application performance, optimize the user experience, and diagnose faults, thereby improving Service quality and providing you with more stable and personalized Services.

2.6 Security-Related Data: We collect and appropriately process data directly related to protecting your account and ensuring the secure use of the Services. This includes, but is not limited to, records of changes to your password, a history of login attempts (including details of successful and failed logins), and other data that may reveal unusual account activity. We may use your account data, device data, Service log data, and data that our affiliates and partners are authorized by you or legally permitted to provide to determine account status and transaction security, verify identity, identify violations of laws or regulations, detect and prevent security incidents, and take necessary recording, analysis, and response measures in accordance with law. Such data is collected to ensure Platform security, prevent unauthorized access, detect potential security threats, and promptly respond to any risk that may compromise your account or the overall security of the Platform.

2.7 Usage Data: When you use the ToonBox Services, we automatically collect data about the videos you watch, your browsing history, search keywords, the number of times you view advertisements and your frequency of interaction with them, the time and frequency of your use of ToonBox, your interactions with other users, your transaction data, data you bookmark/share, and/or other interaction data generated during your use of ToonBox.

2.8 Payment Data: If you purchase our membership Services or other paid content, we may need to collect your payment data to process your purchase and related activities. Third-party payment service providers that cooperate with us (such as Apple Pay and Google Pay) provide us with your payment data so that we can verify your payment status and provide the purchased Services. Please note that we collect data about the products you have purchased, payment transaction numbers, channel IDs, and similar data, but do not collect payment data such as your bank card number or payment password.

2.9 Service Data: When you request technical support and/or customer service support from us, and when you exercise your data subject rights under laws and regulations, we may ask you to provide the personal data necessary to match and verify your user identity. We collect relevant data that you provide when communicating with customer service, including but not limited to details of your Service request, contact details, communication/call records, and any additional data necessary to resolve your issue. This is to ensure that we can respond effectively to your needs and provide accurate and appropriate Service support.

2.10 Personalized Advertising Data and Recommendation Services: After obtaining consent as required by applicable law or establishing another lawful basis for processing, we may process advertising identifiers on your device (such as IDFA and AAID, depending on the operating system), as well as your interests, browsing and search history, device data, usage habits, approximate location data, order data, and similar data, to provide personalized content or advertisements, measure advertising effectiveness, and control display frequency. We limit the scope of processing in accordance with the principle of data minimization and will not make decisions that produce legal effects or similarly significant effects on you solely through automated processing. You may disable personalized recommendations, limit ad tracking, or withdraw the relevant consent through the privacy or advertising settings in ToonBox, your device’s system settings, or the contact details set out in Section 10 of this Policy. After doing so, you may still see non-personalized advertisements or general content recommendations.

2.11 Survey and Promotional Data: If you choose to participate in our surveys, promotions, marketing, or similar activities, we collect the data you provide and data about your participation, including your name, email address, mobile phone number, nickname, and country or region.

2.12 Circumstances in Which Consent Is Not Legally Required for the Collection and Use of Personal Data:

Please understand that, in the following circumstances, we are not required to obtain your prior authorization or consent to collect, use, disclose, share, or transfer your personal data under laws and regulations, relevant national standards, and the requirements of market regulatory and judicial authorities:

(1) Where it relates to our performance of obligations prescribed by laws and regulations;

(2) Where it is necessary to enter into or perform a contract to which you are a party;

(3) Where it is directly related to public security, public health, or significant public interests;

(4) Where it is directly related to criminal investigations, public prosecutions, criminal trials, or the enforcement of judgments;

(5) Where it is directly related to civil proceedings, civil trials, or the enforcement of judgments;

(6) Where it is directly related to market regulation, administrative penalties, or the enforcement of administrative penalties;

(7) Where it is necessary to protect your or another person’s life, property, or other significant lawful rights and interests, and it is difficult to obtain the individual’s consent promptly;

(8) Personal data that you have made public yourself;

(9) Data collected from lawfully and publicly disclosed information, such as public government information and public information on social media platforms.

(10) Where it is necessary to maintain the secure and stable operation of the software and related Services, such as detecting and resolving faults in the software and related Services;

(11) Where it is necessary for lawful news reporting;

(12) Where it is necessary for an academic research institution to conduct statistical or academic research in the public interest, provided that personal data contained in results supplied externally for academic research or descriptive purposes is de-identified;

(13) Other circumstances prescribed by applicable laws and regulations.

2.13 Other Data Requiring Special Notice: For certain specific Services we provide, we may collect data other than that described above to support their distinctive features or functions. In such cases, we will formulate a separate privacy notice or policy for the specific Service, explaining how we collect, use, store, and protect your personal data when you use that Service. If there is any discrepancy between the privacy notice for a specific Service and this general Privacy Agreement, the privacy notice for the specific Service will prevail.

2.14 You understand and agree that, in specific circumstances, after collecting relevant data, we will use technical means to de-identify and anonymize it. The processed data cannot be directly or indirectly associated with you or any other person and therefore no longer constitutes personal data directly or indirectly relating to you or another person. On this basis, and subject to compliance with relevant laws and regulations, we reserve the right to use such anonymized data for activities such as data analysis, market trend research, and enhancement of the value of our user database, so as to continuously optimize our Services and user experience while ensuring that personal privacy is fully protected.

2.15 Description of Floating Window Permission Use: This application requests the “display over other apps” floating window permission solely for picture-in-picture video playback. This permission is used only to continue playing a video after you leave the playback page and will not be used to collect, store, or transmit any personal data. You may enable or disable this permission at any time in your system settings. Disabling it will affect only picture-in-picture playback and will not affect other application features.

3. Purposes for Which We Collect and Use Personal Data

3.1 As necessary to enter into, perform, and enforce an agreement with you;

3.2 To help you create, log in to, and manage your account and maintain your personal data, and to enable you to use our various Services and Platform-related features through your account;

3.3 To enable us to provide, manage, process, maintain, research, develop, and improve the Services (including optimization of playback features such as film and television content and picture-in-picture, advertising, paid Services, system administration, user services, archiving, and/or backup purposes);

3.4 To communicate with you and provide personalized recommendation Services (including film and television content and advertisements), including sending you commercial marketing materials and displaying advertisements that may be relevant to your interests, operational campaign notices, notices of updates to agreement texts, or other data relating to our Services;

3.5 To evaluate your applications relating to the ToonBox Services and respond to your questions/inquiries/feedback/disputes;

3.6 To verify and execute transactions relating to your online payments;

3.7 To monitor, prevent, or investigate fraud, abuse, security risks, and technical issues that may harm ToonBox, you, or the public; verify the authenticity of account owners; protect the security of your account, ToonBox Platform users, and the ToonBox Services and systems; and improve the security and reliability of the ToonBox Services;

3.8 To analyze, profile, segment, combine, and/or update all collected data (whether in aggregated or personalized form) to improve Service quality and provide a better experience;

3.9 To respond to requests from government authorities or fulfill obligations prescribed by applicable laws and regulations;

3.10 For other purposes separately disclosed to you when we collect your data or other purposes to which you have consented.

3.11 For the purposes described above, our affiliates may be engaged to process your data, provided that such affiliates comply with the provisions of this ToonBox User Privacy Agreement.

In this ToonBox User Privacy Agreement, an affiliate means an entity that directly or indirectly controls Spark Deep Intelligence Technology Co., Limited, is directly or indirectly controlled by Spark Deep Intelligence Technology Co., Limited, or is under common control with Spark Deep Intelligence Technology Co., Limited.

4. How We Share and Disclose Your Data

Unless expressly stated otherwise in this Policy, actively requested or consented to by you, or otherwise provided by applicable law, we will not share or disclose your personal data. We may share or disclose your personal data in the following circumstances:

4.1 Your Own Disclosure and Sharing of Your Data

4.1.1 Personal data that you set and publicly display on your ToonBox profile page (which may include your gender, nickname, profile picture, and other data).

4.1.2 You may use the ToonBox Services to share your personal data or other data with third parties (including unspecified recipients). When using ToonBox’s sharing feature, you may choose to share relevant data by methods permitted by the Platform (such as email, SMS, social applications such as Facebook, or other applications). Once data leaves ToonBox and is received by a third party, that third party will process the relevant data independently in accordance with its terms of service and privacy policy. We recommend that, before sharing, you carefully confirm the recipient, scope of sharing, and applicable third-party rules. We will bear corresponding responsibility under law for the sharing features and data processing activities that we provide. Risks arising from independent processing by a third party or from your own public sharing will be addressed in accordance with applicable law and the respective scope of responsibility of each party.

4.2 Our Disclosure and Sharing of Your Data

Where one or more of the following circumstances applies, we will disclose or share your personal data with the following third parties in compliance with the applicable legal requirements of this Policy:

4.2.1 Where you actively request sharing or where sharing occurs with your consent;

4.2.2 Where it is necessary to publish disciplinary announcements concerning accounts in violation, fraudulent conduct, or similar matters, or to display relevant data when announcing lists of prize recipients/winners.

4.2.3 Sharing Data with Business Partners:

You understand and acknowledge that some of our Services may be provided by business partners or jointly by us and our business partners. We provide necessary personal data to the following partners for the purposes described in this Policy only where there is an appropriate legal basis, the principle of data minimization is observed, and necessary protective measures are taken. Where required by applicable law, we will separately inform you of the recipient, data types, and processing purposes and obtain your consent:

(1) Service providers, such as marketing agencies providing marketing services, payment institutions providing payment services, logistics service providers, and other partners providing functional support for the Services.

(2) Data processors (including data processors providing online advertising data monitoring, data statistics, data analysis, and other services). To analyze, maintain, and improve our Services and provide you with better content, we may share your relevant data with designated partners that provide such services.

(3) Advertising partners. In the course of working with partners to deliver advertisements, we share data such as device IDs, advertising device identifiers, user age and gender labels, and IP addresses with them to assist with advertising or decision-making recommendations, improve the effective reach of advertisements, and further understand user needs.

You may manage your personalized advertising preferences by limiting ad tracking through your device settings or resetting the advertising identifier on your Apple or Android device. For more information about how to change the relevant settings, please refer to:

• iOS: Please refer to the advertising and privacy settings instructions provided by Apple

• Android: https://support.google.com/ads/answer/2662922

Please note: Adjusting your preferences does not mean that you will no longer receive advertisements. It only means that the advertisements you see will be less relevant to your interests. Our advertising partners will still use your device’s advertising ID to show you advertisements that may be less relevant to you. For example, we may use this feature for frequency capping (in other words, controlling the maximum number of times you see the same advertisement from us). You may also reset the advertising ID associated with your device by following the instructions provided by the device manufacturer or operating system developer.

(4) Operational campaign service partners. For example, when conducting joint marketing campaigns with third parties, we may share data relating to prize recipients/winners in the joint marketing campaign (such as your name and other data) so that they can promptly distribute prizes/gifts to you.

(5) Third-party SDK service providers: Our products may contain third-party software development kits (SDKs), application programming interfaces (APIs), or other similar components. Such components may directly collect or process necessary data according to their functions. We conduct necessary security and compliance assessments of third parties in accordance with applicable law, contractually restrict their processing purposes, scope, and retention periods, and obtain your consent where legally required. Where a third party processes data as an independent data controller, its activities are governed by its own privacy policy. We will nevertheless bear corresponding responsibility under law for our selection, integration, and management of third-party components. We recommend that you read their privacy policies before enabling the relevant features. If you identify any risk associated with a relevant component, please stop using it and contact us.

Third-Party SDK Directory

SDK Name: Facebook Login SDK

Purpose of Use: User account registration and login

https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

SDK Name: Google Sign-In SDK

Purpose of Use: User account registration and login

SDK Name: AppsFlyer SDK

Purpose of Use: Advertising attribution and deep-link acquisition for media platforms (redirecting to a specified page/)

SDK Name: Firebase SDK

Purpose of Use: Push notifications and collection of application errors

SDK Name: Apple Pay SDK

Purpose of Use: Apple Pay payments (iOS only)

SDK Name: Sign in with Apple SDK

Purpose of Use: Sign in with Apple (iOS only)

SDK Name: Skyengine Analytics SDK

Purpose of Use: Application analytics services that enable us to obtain and collect statistics concerning the use of our application so that we can better understand how users use our application. For this purpose, through the Skyengine Analytics SDK, we collect your device information (Android ID/IDFA/IDFV/UUID), the type and version of the operating system ("OS"), OS language, your unique device ID, your time zone, and your device’s screen size. Skyengine Analytics

SDK will process your non-identifiable user ID.

SDK Name: MPABTestSDK

Purpose of Use: Application experimentation and optimization services that enable us to conduct A/B testing by randomly assigning users to different experimental groups, allowing us to compare the effects of different features, interfaces, or recommendation strategies and helping us optimize the application experience and business performance.

https://abtest-console.skyengine.com.cn/ab-sdk-privacy-policy/index.html

SDK Name: Volcengine SDK

Purpose of Use: Video stream decoding and playback.

SDK Name: BytePlus TTS SDK

Purpose of Use: Converting text entered by users into speech audio in real time. This SDK transmits only the text content used for speech synthesis to BytePlus servers and does not actively collect personal sensitive data such as user identity data, contacts, or location. Text data used for synthesis is used solely to perform real-time text-to-speech conversion. Under the provider’s current rules, BytePlus does not permanently store such text by default. You may disable the text-to-speech feature at any time to stop the relevant data transmission.

Description of Interactions with Third-Party Applications

We provide you with a convenient “quickly follow a specified account” feature. Our application may invoke third-party applications installed on your device (including Instagram, YouTube, and TikTok). This invocation only redirects you to the follow page for the specified account in the relevant application and does not collect, store, or transmit any of your personal information (such as account information, device identifiers, or browsing history).

After the redirect, your activities within the third-party application (including following and logging in) will be governed by that application’s own privacy policy and user agreement. We neither participate in nor interfere with the relevant activities of third-party applications.

(6) Other business partners.

You understand and agree that such third-party business partners (“third parties” or “contractors”) may use Cookies, web beacons, and/or other tracking technologies to collect, receive, process, and retain data about you. For example, users who purchase and/or subscribe to products or Services will need to provide third-party payment contractors with additional data, such as a valid credit card number and expiration date, to process payments and resolve subsequent payment disputes and inquiries. We will also participate in this process and may receive, process, and store data provided by you and/or such third-party contractors to confirm payments, record purchase history and other Service details, and/or protect our legitimate interests when resolving subsequent related Service or payment disputes and inquiries.

Where a specific third party collects or processes data, please refer to the privacy policy on its official website for detailed information about its data processing rules.

4.2.4 Disclosure or Sharing of Your Data as Required by Law or Regulation:

(1) Necessary disclosures made to comply with court judgments or other legal procedures, requirements of relevant government authorities or legally authorized organizations, legal requirements, or other reasonable grounds. In certain circumstances, we may share your personal data with third parties (such as judicial authorities, law enforcement agencies, government agencies, or other similar third parties) as required by law or by government departments or regulatory authorities, to protect you, other Platform users, and our lawful rights and interests, or to protect public interests, property, or safety from harm.

(2) Where sharing your personal data is the only way to implement the features of our Services, provide the Services you require, or handle disputes or controversies involving you;

(3) Where your personal data is shared pursuant to relevant agreements entered into between you and us (such as online agreements and Platform rules) or other legal documents;

(4) Where the data we share has been de-identified and the third party receiving the shared data cannot re-identify the data subject, where the personal data has been made public by you, or where we have collected it from lawful public sources;

(5) Other circumstances prescribed by laws and regulations or required by regulatory authorities.

4.2.5 Subject to applicable laws and regulations, if we determine in good faith that disclosing such data is indispensable for any of the following purposes, we reserve the right to disclose or share your personal data in specific circumstances without obtaining your authorization:

(1) You have breached any agreement with us, including the Terms of Service or this ToonBox User Privacy Agreement, or have harmed our legitimate interests;

(2) Your conduct infringes a third party’s intellectual property rights or other rights and interests;

(3) Matters relating to Section 2.12 of this Policy.

4.2.6 Where public disclosure is otherwise genuinely necessary on reasonable grounds, we will inform you of the purpose and type of the data to be publicly disclosed before such disclosure and will make the public disclosure only after obtaining your authorization and consent.

5. Cookies and Similar Technologies

5.1 Cookies are small data files stored on your device through online services by us or third-party service providers. When you log in to and use a website or other online content, we or our third-party partners may use relevant technologies to send one or more Cookies or anonymous identifiers to your device and store them on your computer, mobile device, or other device (usually in encrypted form) to collect, identify, and store data concerning your access to and use of this product and retain such data as records. Technologies similar to Cookies are other technologies, such as embedded scripts, that can be used for similar purposes. In this Policy, we collectively refer to all such technologies as “Cookies.”

5.2 We use Cookies to optimize our Services, improve users’ product experience, and for various other purposes, including:

(1) Recording you and your IP address and simplifying operational steps (such as keeping you logged in);

(2) Protecting your account data and enabling our products and Services to operate securely and efficiently;

(3) Collecting technical data about the devices and software you use to access the ToonBox Services;

(4) Measuring and analyzing the content you click and how you use the Platform;

(5) Retaining preferences or data that you previously provided in order to recommend, display, and push content that may interest you;

(6) Monitoring visitor traffic to our Platform; operating, measuring, analyzing, and optimizing the advertising performance of our Platform; and improving Platform performance;

(7) Other related functions or purposes set out in this Policy.

5.3 If you do not wish to accept Cookies or wish to be notified when Cookies are placed, you may manage or delete stored Cookies through the relevant features provided by your browser, device, or the product. Essential Cookies are used for login, security protection, and core functionality, and disabling them may prevent certain Services from functioning properly. Analytics, advertising, and other non-essential Cookies will be used with your consent in accordance with applicable law, and you may withdraw or adjust your choices at any time through the Cookie settings. Withdrawal of consent does not affect the lawfulness of processing conducted before the withdrawal.

6. How We Store and Protect Your Personal Data

6.1 Storage Locations

The current server locations for the ToonBox Services include Japan. At the same time, in view of future expansion plans, this Policy also covers any server locations that may be added, where data will be securely stored on or transmitted through servers in accordance with local regulatory requirements.

6.2 Third-Party Sharing and Cross-Border Data Transfers

To provide global Services, after establishing an appropriate legal basis and completing any notice, impact assessment, regulatory approval, or consent procedures required by applicable law, we may transfer your personal data to our business operations departments, engineering and technical teams, subsidiaries, third-party service providers, and partners operating worldwide. Recipients may be located in the storage locations described above or outside your jurisdiction, and local data protection laws may differ from those in your location. We will implement the cross-border transfer mechanisms and security measures required by applicable law and will transfer only the data necessary to achieve the specific purpose.

When processing data across borders, we comply with applicable laws and regulations and take necessary protective measures to ensure data security, such as:

(1) Using the Standard Contractual Clauses (SCCs) approved by the European Commission as part of data transfer agreements to ensure that data processors comply with European Union data protection standards.

(2) Where applicable, using cross-border transfer mechanisms recognized by competent authorities, such as binding corporate rules, adequacy decisions, approved certification mechanisms, or other lawful transfer tools, and conducting necessary assessments of recipients’ data protection capabilities.

(3) We implement technical and organizational security measures no less stringent than those required by applicable data protection laws of the Hong Kong Special Administrative Region of China, including encryption, access controls, tiered permissions, and data segregation, to protect the security of personal data.

(4) The Company has established strict internal data transfer management systems, including but not limited to data protection agreement systems and data transfer approval procedures, to ensure the lawfulness and security of data transfers and protection.

6.3 Retention Period

In general, we retain your personal data only for the period necessary to provide the Services or for a longer period prescribed by law. After the above retention period expires, we delete or anonymize your personal data as required by relevant laws and regulations.

However, in the following circumstances, we may need to adjust the retention period for personal data in accordance with legal requirements:

(1) To comply with applicable laws, regulations, and other relevant provisions;

(2) To comply with court judgments, rulings, or other legal procedures;

(3) To comply with the requirements of relevant government authorities or legally authorized organizations;

(4) Where we have reason to believe that extending the data retention period is necessary to comply with laws and regulations or protect lawful rights and interests;

(5) To enforce the User Agreement or this Policy, or for the purpose of safeguarding public interests or protecting the personal and property safety and other lawful rights and interests of us, our affiliates, partners, other users, or employees.

(6) If our products or Services cease operation, we will notify you through push notifications, announcements, or other means and delete or anonymize your personal data within a reasonable period.

6.4 Special Notice for Canadian Users: After using your personal data to make a decision that directly affects you, we undertake to retain that data for at least one year in order to provide you with a sufficient opportunity to access the data on which the relevant decision was based. This means that, even if you subsequently withdraw or change your authorization and consent for us to collect, process, share, or publicly disclose your personal data, we reserve the right to continue retaining such data where there is a reasonable legal basis to do so.

6.5 Measures We Take to Protect Personal Data:

6.5.1 We have adopted industry-standard technical security measures, encryption technologies, and other reasonable and practicable means, and have established relevant security departments, management systems, and procedures to protect the security of your personal data and minimize the risk of data leakage, damage, misuse, unauthorized access, unauthorized disclosure, and alteration, including but not limited to:

(1) If laws and regulations or this Policy require us to obtain your authorization and consent again before sharing your data with a third party, we will inform you of the type and purpose of the data to be shared, the recipient, and other relevant matters before sharing and will share the data only after obtaining your authorization and consent;

(2) We contractually bind our partners to their obligations and legal responsibilities concerning personal data protection;

(3) Our security team conducts security assessments and processing with respect to the form, transfer, and use of data and endeavors to anonymize personal data;

(4) If, as a result of the sharing and disclosure described in this Policy, your data may be transferred to another country or region, whether to our affiliates or third-party business partners, we comply with relevant applicable law to ensure that all such cross-border data transfers satisfy the requirements of locally applicable data protection laws.

6.5.2 Please acknowledge and understand that the internet environment involves inherent risks and that no system can guarantee absolute security. Although we take reasonable protective measures consistent with applicable law and industry standards, hacking, technical vulnerabilities, accidents, or other security incidents may still occur. If a security incident involving or potentially involving the leakage, damage, or loss of personal data occurs, we will take remedial measures in accordance with law, assess the potential impact, and report the incident to competent authorities and notify affected users where required by applicable law. We will bear corresponding liability under law for damage caused by our own unlawful conduct, willful misconduct, or negligence.

Accordingly, we strongly recommend that you take proactive measures, such as using a complex password and avoiding sensitive operations over unsecured networks in public places, to work with us in safeguarding your account. If you discover that your personal data has been leaked or encounter a similar situation, please contact us immediately so that we can take appropriate measures to protect your data security and personal privacy.

7. Your Rights and Choices

7.1 Notifications and Choices

You acknowledge and agree that, when you use the ToonBox Services, we may use the contact details you provide (including but not limited to your telephone number and email address) to send various notifications and information for purposes such as user communications, identity verification, security verification, user experience surveys, advertising, or marketing campaigns.

You may stop receiving marketing or promotional messages through the unsubscribe link in the relevant information, system interface settings, or other operational instructions provided by us. Essential non-marketing notifications concerning transactions, security, Service status, or material updates to agreements may not be affected by marketing opt-out settings. If you disable push notifications at the device level, you may be unable to receive such important notifications promptly.

7.2 Right to Review/Access and Manage Personal Data

On the personal data page, you may review the types of your personal data that we collect, the purposes and status of collection, and the specific data, such as your basic data and transaction records. You may also review your usage data on relevant product pages, such as bookmarked content, viewing history, and offline download records (if an offline download feature is provided).

You have the right to correct/modify certain personal data in our Services by following the operational instructions and settings provided on the relevant product feature pages.

7.3 Right to Withdraw Authorization and Consent

Certain business features and Services require your personal data in order to function. After you withdraw your consent or authorization, we will be unable to continue providing the corresponding features and Services and will cease processing the corresponding personal data. However, your decision to withdraw consent or authorization will not affect personal data processing previously conducted on the basis of your authorization.

7.4 Right to Request Deletion of Personal Data

7.4.1 You have the right to delete your personal data retained by us in connection with the Services. You may use the deletion feature built into ToonBox or contact us to delete certain usage data, or exercise this right by deleting your account. Please note, however, that data about you shared by others does not form part of your account data and is therefore outside the scope of deletion.

Before formally deleting your account, we may need to verify your identity, account security status, and associated device data to ensure the security of the operation. After you delete your account, we will delete or anonymize your relevant data, except as otherwise provided by laws and regulations. You understand and agree that, once your account is deleted, it and all corresponding data cannot be restored. You will lose access to the relevant Services, account data, subscribed content, motion comic data, personal data, and other materials and will be unable to access other Services through that account.

7.4.2 You understand and agree that, due to technical constraints and limitations under applicable law, after you delete data, the data may temporarily remain in backup systems. We will store such data in isolation until it is securely deleted or anonymized when the backups are updated.

7.4.3 In certain circumstances, such as where necessary to comply with legal obligations, resolve disputes, or enforce agreements, we may retain certain data for a period permitted by law.

7.5 Right to Restrict or Object to Processing

Where provided by applicable law, you have the right to request that we restrict the processing of your personal data or to object to processing based on legitimate interests, including the use of your personal data for direct marketing. Upon receiving your request, we will assess and process it in accordance with applicable law. If we have compelling grounds under law to continue processing, we will explain them to you.

7.6 Right to Data Portability

Where provided by applicable law, you have the right to request and receive the personal data you have provided to us in a structured, commonly used, and machine-readable format or to request that we transmit such data directly to a third party designated by you where technically feasible.

7.7 Rights Relating to Automated Decision-Making

If we make a decision that produces legal effects or similarly significant effects on you solely through automated processing, you may, in accordance with applicable law, request that we provide a relevant explanation, conduct human review, allow you to express your views, or allow you to challenge the decision.

7.8 Right to Lodge a Complaint

If you believe that the way we process your personal data violates applicable law, you may first contact us using the methods set out in Section 10 of this Policy. You may also lodge a complaint in accordance with law with the data protection authority in your location or another relevant jurisdiction.

7.9 Verification of and Responses to Rights Requests

To protect the security of your account and personal data, we may verify your identity and authorization before processing your request. We generally respond within the period prescribed by applicable law. If an extension is required due to the complexity or number of requests, we will notify you in accordance with applicable law. Except in circumstances permitted by law, we generally do not charge a fee for reasonable rights requests.

8. Age Restrictions

8.1 Children under the age of 13 may not register for, log in to, access, or use ToonBox or its related Services and may not provide us with any personal data, including but not limited to a name, address, telephone number, or email address. If the age of digital consent under the laws of your location is higher than 13, the higher age threshold prescribed by local law will apply.

8.2 Minors who are at least 13 but under 18 years of age must, where required by applicable law, obtain the prior consent of a parent or legal guardian and, under their supervision and guidance, read this ToonBox User Privacy Agreement, create an account, and use ToonBox and its related Services. If applicable law permits minors who have reached a specified age to consent to the processing of their personal data independently, such law will apply.

8.3 To confirm whether users meet the age requirements described above, we may take reasonable and risk-proportionate age-verification measures to the extent permitted by applicable law. Where applicable law requires parental or guardian consent, we may require the parent or guardian to complete a verifiable consent process. If the necessary age verification or parental or guardian consent process cannot be completed, we may refuse to create an account, restrict relevant features, or discontinue the Services.

8.4 If we discover or have reasonable grounds to believe that we have collected personal data from a child below the applicable age of digital consent without obtaining valid parental or guardian consent, we will take reasonable measures to delete or anonymize the relevant data as soon as possible and, as appropriate, disable or delete the relevant account.

8.5 If you are the parent or legal guardian of a minor, you should read and understand this ToonBox User Privacy Agreement together with the minor, assist the minor in completing any necessary consent process, and supervise the minor to ensure that they access only age-appropriate content and make reasonable use of purchasing and other features. You may use the contact details set out in this Policy to inquire whether we hold personal data relating to the minor and request access to, correction of, or deletion of such data in accordance with applicable law.

8.6 If you believe that we have improperly collected or retained the personal data of a child or minor, please contact us as soon as possible using the contact details set out in Section 10 of this Policy. After verifying the identity of the applicant and their relationship with the minor, we will handle the relevant request in accordance with applicable law.

9. Other Provisions

9.1 Scope of This Policy

This ToonBox User Privacy Agreement applies only to data processing activities that we conduct as a data controller or an entity legally responsible for such processing and does not apply to third-party products or services that expressly display or refer to another privacy policy. Our Services may integrate with or link to third-party platform resources, such as third-party features, advertisements, applications, or websites. Third parties independently process relevant data in accordance with their own privacy policies. We do not control their independent processing activities, but we will bear corresponding responsibility under law for our selection or integration of third parties or provision of data to them. We recommend that you read and understand a third party’s privacy policy before providing personal data to it.

9.2 Updates to This Policy

We may update this ToonBox User Privacy Agreement from time to time and will notify you in an appropriate manner, such as through an announcement, pop-up window, push notification, or email, in accordance with applicable law. If an update involves material changes to processing purposes, data types, recipients, cross-border transfer methods, or your rights, we will explain the changes prominently. If the law requires us to obtain consent again, we will separately obtain your consent before the relevant processing begins. You may determine whether this Policy has been revised by referring to the last updated date stated in it and may decide whether to continue using the relevant Services based on the options provided in the product and applicable law.

9.3 Data Transfers

If we undergo a merger, acquisition, reorganization, demerger, bankruptcy, asset transfer, or similar event, your personal data may be transferred to a successor. We will notify you and require the successor to continue complying with and performing this Policy. If the successor needs to process your personal data beyond the scope authorized by this ToonBox User Privacy Agreement, the successor will be responsible for informing you of the details of its proposed processing and obtaining your consent again or anew in accordance with applicable laws and regulations. Where minors are involved, the successor must also obtain the consent of their parents or legal guardians.

9.4 Governing Law and Dispute Resolution

The interpretation, performance, and dispute resolution of this ToonBox User Privacy Agreement are governed by the laws of the Hong Kong Special Administrative Region of China, provided that this will not deprive you of rights available under the mandatory consumer protection or data protection laws of your location. If a dispute arises between you and us, the parties shall first seek to resolve it through amicable consultation. If consultation fails, the dispute may, to the extent permitted by applicable law, be submitted to the Hong Kong International Arbitration Centre and handled in accordance with the arbitration rules in effect when arbitration is commenced. If applicable law grants you a non-waivable right to lodge a complaint or bring proceedings before a court, competent authority, or data protection authority in your location, this provision does not restrict that right.

10. Contact and Complaints

10.1 If you have any questions, comments, or suggestions concerning this ToonBox User Privacy Agreement, any issues concerning the protection of your personal data, or wish to exercise your rights under this Policy, please contact us as follows:

Email address: service@toonbox.com. We will review the matter as soon as possible and respond promptly after verifying your user identity.