Privacy Policy

This Privacy Policy (referred to as this “Policy”) was issued and became effective on January 15, 2024.

This Policy constitutes a valid agreement regarding the protection of privacy and personal information in connection with the CC short application (hereinafter referred to as the “Product”) between CC Information Technology Co., Limited and ZAI Creative LLC (collectively referred to as “we,” “us,” or “our”) and each user of the Product (also referred to as “you” or “your”).

The registered address of ZAI Creative LLC is:

30 N Gould St., Sheridan, WY 81801, United States

By clicking to confirm this Policy, using the Product, or otherwise accepting this Policy, you acknowledge that you have read, understood, and agreed to all provisions of this Policy.

CC Information Technology Co., Limited and ZAI Creative LLC are the registered copyright owners of the Product and own the copyright and other related intellectual property rights in the Product in accordance with applicable laws.

The Product is operated, and the related services are provided, by CC Information Technology Co., Limited and ZAI Creative LLC. The companies shall undertake their respective rights, obligations, and legal responsibilities in connection with the operation of the Product, the provision of services, and the processing of users’ personal information in accordance with applicable laws.

This Policy will help you understand the following:

  1. How we collect and use your personal information;
  2. How we use cookies and similar technologies;
  3. How we share, transfer, and publicly disclose your personal information;
  4. How we protect and store your personal information;
  5. Your rights;
  6. How we handle children’s personal information;
  7. How your personal information is transferred globally;
  8. How this Policy will be updated;
  9. Application of this Policy; and
  10. Contact us.

CC Information Technology Co., Limited and ZAI Creative LLC attach great importance to the protection of your personal information. When you use our products or services, we may collect and use information relating to you.

Once you choose to use our products or services, you acknowledge and accept the current contents of this Policy and any contents that may be updated from time to time. If you do not agree with this Policy, you should stop using the Product and its related services.

Please read and understand this Privacy Policy carefully before using our products or services.

I. How We Collect and Use Your Personal Information

Personal information means information recorded electronically or by other means that, alone or in combination with other information, identifies a specific natural person or reflects the activities of a specific natural person.

CC Information Technology Co., Limited and ZAI Creative LLC will only collect and use your personal information when providing services to you for the purposes, in the methods, and within the scope described in this Policy.

To inform you about the collection of personal information in a more concise, clear, and accessible manner, we may also provide you with an Explicit List of Personal Information Collection, which you may access for further details.

1. Application Function 1: Becoming a Registered User of CC short

When you apply to become a registered user of the Product, you may be required to provide device-related information.

The information you provide authorizes us to continue using it for as long as we provide the relevant services to you.

When you cancel your account, we will stop using and delete the above information, unless its continued retention is required or permitted by applicable laws and regulations.

2. Application Function 2: Personalized Recommendations, User Profiles, and Advertising Functions

When you use our services, the Product may record your operation logs, including:

Based on the above information, we may analyze your preferences, viewing habits, characteristics of your use of the Product, and user profile in order to provide personalized and customized services and to display or recommend services and content that may be more relevant to you.

You may turn off personalized recommendations through “My” – “Settings” – “Personalized Recommendations.”

Turning off personalized recommendations will not affect your use of the other basic functions of the Product.

3. Application Function 3: Ordering and Payment

When you use the Product to order VIP memberships or paid drama services, records generated during the ordering and payment process may be stored on our servers.

These records may include:

The above information is necessary for us to provide the relevant ordering, payment, purchase, and viewing functions.

If you do not agree to our recording and processing of the above information, we may be unable to provide short-drama purchase, membership, payment, or viewing services to you.

4. Application Function 4: Displaying Your Nickname and Avatar

When you use TikTok or Facebook to log in to the Product, we may obtain and record your nickname and avatar for display in the personal center, membership page, or other relevant areas of the Product.

If you do not want us to obtain your nickname and avatar, you may choose not to use TikTok or Facebook to log in to the Product.

5. Application Function 5: Sharing Pages with TikTok or Facebook Friends

To enable users to share or save content through TikTok or Facebook, including sharing pictures or other content with TikTok or Facebook friends or saving such content to TikTok or Facebook collections, we may collect and transmit the pictures or content actively selected by users to the TikTok or Facebook application.

During this process, we may also automatically record certain information, including:

We will not use the above information to improperly associate, identify, or track users beyond the purposes described in this Policy.

If you refuse to provide the information or permissions necessary for the sharing function, you may be unable to use the function of sharing or saving content to TikTok or Facebook. Your use of the other functions of the Product will generally not be affected.

6. Application Function 6: Security Services

To provide safe and stable services, protect the security of your account and property, prevent fraudulent or unauthorized login, and ensure the normal operation of the Product, we may automatically record certain information when you use our products or services.

Such information may include:

If you do not agree to our collection of device configuration information, IP address information, or software version information, we may be unable to complete necessary risk-control or security-verification processes, and certain functions of the Product may be unavailable.

If you do not agree to our collection of device unique identifier information, we may be unable to complete the registration, login, fraud-prevention, or security-verification process.

7. Application Function 7: Permission Enablement

CC Information Technology Co., Limited and ZAI Creative LLC undertake not to collect your personal information beyond the scope or frequency necessary for the purposes described in this Policy.

We will not intentionally collect information that is unnecessary for the use of our products and services or that is not reasonably related to the functions provided.

When you use the Product, we may request access to certain permissions on your terminal device in specific usage scenarios in order to provide the relevant services.

You may refuse to grant the requested permissions or disable the permissions through your device settings.

Disabling a permission may prevent you from using the function corresponding to that permission but generally will not affect your use of other unrelated functions of the Product.

The permissions that the Product may request include the following:

Access to Phone or Device Status

By obtaining phone or device-status permission, we may record device identification information, such as an IMEI or IMSI code, where permitted by applicable law.

Such information may be anonymized or otherwise processed for statistical analysis, fraud prevention, and security verification.

Access to Local Storage

By enabling local-storage permission, you may download episodes or other permitted content from the Product to your mobile device.

Access to Photos

You may select photos or pictures directly from your device for uploading, setting an avatar, sharing content, or providing supporting materials when communicating with customer service.

Access to Media Content and Files on Your Device

This permission may be used to read and write episode covers, images, animations, cached files, or other media materials in order to improve the smoothness and performance of the Product.

Enable Push Notifications

You may enable push-notification permission to receive messages, service notices, content updates, activity information, or other notifications from the Product.

You may disable this permission at any time through your device settings.

Enable Wireless or Cellular Data

You may connect to a wireless network or cellular network to use the networking functions required by the Product.

Access to the Installed Application List

Where permitted by applicable law and authorized by you, we may access limited information regarding installed applications to confirm whether you have installed certain products or applications that we promote, so that we may provide corresponding rewards or complete relevant attribution and security functions.

Enable Microphone and Voice Recognition

You may enable microphone or voice-recognition permission to use voice reading, voice control, customer-service communication, or other voice-related functions of the Product.

Enable Siri and Search

You may enable Siri and Search to retrieve or access content from the Product through supported system functions.

Enable Background Application Refresh

You may enable background application refresh to support functions such as audio drama listening or background playback, so that playback is not interrupted solely because the Product is switched to the background.

Use of Clipboard

You may use the clipboard to copy and paste customer-service information, invitation codes, links, or other text.

Where required by the operating system or applicable law, the Product will request your authorization before reading clipboard contents.

You may choose not to use clipboard-related functions.

Use of Gyroscope, Acceleration Sensor, and Orientation Sensor

These sensors may be used to detect changes in the horizontal or vertical orientation of the device during video playback and to support screen rotation or other related functions.

Network Access

The Product may obtain network-access permission for functions such as content loading, dictionaries, encyclopedias, voice reading, account services, payments, advertisements, and other online services.

Associated Startup of Other Applications

When you use certain functions, the Product may trigger the startup of another application.

For example, when you choose to log in through TikTok or Facebook on the login page, the Product may start the relevant TikTok or Facebook application to obtain your login authorization.

Permissions Required for Third-Party SDK Services

Our products and services may include third-party software development kits, products, services, or links to third-party websites.

When you use these products or services, the relevant third parties may collect your information in accordance with their own privacy policies.

After obtaining your authorization or consent where required, we may provide the personal information necessary to enable the relevant third-party service.

If the identity of a relevant third party or the purpose of processing materially changes, we will obtain your consent again where required by applicable law.

II. How We Use Cookies and Similar Technologies

Cookies and anonymous identifier tools are mechanisms that support a server or script in storing and retrieving information on a client device.

When you use our products or services, we may send one or more cookies or anonymous identifiers to your device.

When you interact with our services, cookies or anonymous identifiers may transmit relevant information to servers operated by CC Information Technology Co., Limited and ZAI Creative LLC or our authorized service providers.

Cookies generally contain identifiers, website or application names, and certain numbers and characters.

Through cookie technology, we may understand usage habits, remember preferences, reduce the need to repeatedly enter the same information, help assess account security, measure traffic, and analyze the effectiveness of page or product design.

We may use cookies for the following purposes:

1. Identity and Security Verification

We may store your user token on the client device through cookies or similar technologies so that we can verify your account information and protect account security.

For example, cookie technology may enable us to identify whether you have securely logged in when you open the CC short application and to display account-related information when you use the Product.

2. Securing Data and Services

We may use cookies or similar technologies to detect and prevent cheating, hacking, fraud, unauthorized access, and other conduct that may threaten our products, services, or users.

For example, cookies may store ticket or token information so that the server can verify whether a login to CC short is legitimate.

Cookies and similar technologies may also help prevent certain attacks, cross-site information theft, unauthorized access, and identity impersonation.

3. Providing a Better User Experience

When you log in, information stored through cookies may help fill in the name or identifier of the account most recently used to log in, thereby improving operational efficiency.

4. Page and Content Caching

To improve loading and response speed when you use CC short, we may use cookies or similar technologies to cache some of the pages or content you have previously accessed.

When you open the same page again, certain content may be displayed directly from the cache without being requested from the server again, thereby improving loading speed.

You may manage or clear cookies through the settings provided by your device, operating system, browser, or the Product.

Disabling or clearing certain cookies may affect the normal operation of account login, security verification, preference storage, content caching, or other related functions.

III. How We Share, Transfer, and Publicly Disclose Your Personal Information

1. Sharing

We will not share your personal information with any company, organization, or individual other than CC Information Technology Co., Limited and ZAI Creative LLC, their affiliated companies, and authorized service providers, except in the circumstances described below:

Sharing with Your Explicit Consent

We may share your personal information with another party after obtaining your explicit consent.

Sharing in Accordance with Laws and Regulations

We may share your personal information in accordance with applicable laws and regulations, legal procedures, court orders, or mandatory requirements of competent government or regulatory authorities.

Sharing with Authorized Partners

Certain services may be provided by authorized partners for the purposes described in this Policy.

We may share limited personal information with partners in order to provide customer service, technical support, payment processing, analytics, advertising, content distribution, account login, security services, or an improved user experience.

We will only share personal information for lawful, legitimate, necessary, specific, and clearly defined purposes.

We will only share the personal information necessary to provide the relevant services.

Our partners may not use the shared personal information for purposes unrelated to the services entrusted to them, except where they have independently obtained your lawful authorization or are otherwise permitted by applicable law.

Our partners may include:

We will take reasonable contractual, technical, and management measures to protect the security of personal information shared with our partners.

Where available, you may view additional details about third-party SDKs and the sharing of personal information through our Personal Information Third-Party Sharing List or other disclosures provided within the Product.

2. Transfers

We will not transfer your personal information to any company, organization, or individual except in the following circumstances:

Transfer with Explicit Consent

We may transfer your personal information to another party after obtaining your explicit consent.

Merger, Acquisition, Reorganization, or Bankruptcy Liquidation

If a merger, acquisition, asset transfer, reorganization, bankruptcy liquidation, or similar transaction involves the transfer of personal information, we will require the new company or organization holding your personal information to continue to comply with this Privacy Policy.

If the new company or organization intends to materially change the purposes or methods of processing your personal information, it will be required to obtain your authorization or consent again where required by applicable law.

3. Public Disclosure

We will only publicly disclose your personal information in the following circumstances:

  1. After obtaining your express consent; or
  2. Where disclosure is required or permitted by applicable law, legal procedure, litigation, court order, or a mandatory requirement of a competent government or regulatory authority.

4. Types of Information That May Be Shared or Disclosed

Depending on the relevant function, the types of personal information that may be shared with external parties may include:

The specific categories of information shared will depend on the relevant function, your authorization, and the services provided by the relevant third party.

CC Information Technology Co., Limited and ZAI Creative LLC understand the legal responsibilities associated with the sharing, transfer, and public disclosure of personal information and will take reasonable measures to protect the security of personal information.

IV. How We Protect and Store Your Personal Information

1. Technical Protection Measures

CC Information Technology Co., Limited and ZAI Creative LLC attach great importance to the security of your personal information and will endeavor to adopt reasonable security measures consistent with applicable laws and industry practices to prevent personal information from being accessed without authorization, disclosed, altered, damaged, or lost.

These measures may include, but are not limited to:

We may use encryption technology to improve the security of personal information.

We may use trusted protection mechanisms to prevent personal information from being maliciously attacked.

We may also deploy access-control mechanisms to ensure that only authorized personnel can access personal information within the scope necessary to perform their duties.

2. Security Management Systems

We maintain a data-security management system focused on data and the data life cycle.

We seek to enhance the security of the overall system through measures involving:

We also impose appropriate management requirements on employees, contractors, or outsourced personnel who may have access to personal information.

These measures may include:

3. Account Protection

Your account may include security features.

Please keep your account name, password, verification code, and other authentication information secure and do not disclose them to unauthorized persons.

If you discover that your account has been stolen, used without authorization, or that your personal information may have been leaked, please contact us promptly so that we may take appropriate measures.

4. Handling Personal-Information Security Incidents

Although we take reasonable security measures, please understand that no security measure or information network can guarantee absolute security.

If a personal-information security incident occurs, we will handle it in accordance with applicable laws and regulations.

Where required, we will inform you of:

We may inform you of an incident through telephone, email, push notification, in-application notice, public announcement, or other reasonable means.

If it is difficult to notify affected individuals separately, we may issue a public announcement in a reasonable and effective manner.

We will also report personal-information security incidents to competent regulatory authorities where required by applicable law.

5. Retention Period and Storage Location

We currently store your personal information in mainland United States.

We will take reasonably practicable measures to avoid collecting irrelevant or unnecessary personal information.

We will retain personal information only for the period necessary to fulfill the purposes described in this Policy and for the minimum period required by applicable law, unless a longer retention period is required or permitted by applicable law.

The specific retention period may depend on factors such as:

After the applicable retention period expires, we will delete or anonymize the relevant personal information in accordance with applicable laws and regulations.

V. Your Rights

Subject to applicable laws and regulations, CC Information Technology Co., Limited and ZAI Creative LLC protect your right to exercise the following rights with respect to your personal information.

1. Access to Your Personal Information

You have the right to access certain personal information through the User Center or other functions provided within the Product, except where otherwise provided by applicable laws and regulations.

You may also contact us in accordance with Section V.6, “How We Respond to Your Requests.”

2. Correction of Your Personal Information

If you discover that personal information processed by us is inaccurate or incomplete, you have the right to request that we correct or supplement it, subject to applicable law.

Instructions for requesting correction may be found in Section V.6, “How We Respond to Your Requests.”

3. Deletion of Your Personal Information

You may request that we delete your personal information in the following circumstances:

  1. Our processing of personal information violates applicable laws or regulations;
  2. We collect or use your personal information without obtaining the required consent or other lawful basis;
  3. Our processing of your personal information violates an agreement with you;
  4. You no longer use our products or services or you cancel your account;
  5. We no longer provide the relevant products or services;
  6. The processing purpose has been achieved, cannot be achieved, or is no longer necessary; or
  7. Other circumstances provided by applicable laws and regulations.

Instructions for requesting deletion may be found in Section V.6, “How We Respond to Your Requests.”

If we decide to comply with your deletion request, we may also notify entities to which we provided your personal information and request that they delete it in a timely manner, unless otherwise provided by applicable laws and regulations or unless the relevant entity has independently obtained your lawful authorization.

When you delete information from our services, the corresponding information may not be immediately deleted from backup systems.

We will delete or anonymize such information when the relevant backup systems are updated, unless its continued retention is required by applicable law.

4. Withdrawal of Consent and Disabling Functions

You may change the scope of your authorization for our collection and use of personal information or withdraw your consent by disabling the relevant functions or permissions through the Product or your device settings.

You may also withdraw your authorization for us to continue collecting certain personal information by canceling your account.

Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.

After you withdraw consent for a specific function, we may be unable to continue providing that function, but your use of other functions that do not depend on the withdrawn information will generally not be affected.

Instructions for withdrawing consent and disabling functions may be found in Section V.6, “How We Respond to Your Requests.”

5. Account Cancellation

You may cancel your account through:

“App” – “Settings” – “Account Cancellation”

or through another account-cancellation function provided within the Product.

You may cancel a previously registered account at any time, subject to completion of necessary identity and security verification.

After your account is canceled, we will stop providing products or services associated with the account and will delete or anonymize your personal information, unless its continued retention is required or permitted by applicable laws and regulations.

We may be unable to comply with a request to delete personal information in the following circumstances:

  1. The information is directly related to national security or national defense security;
  2. The information is directly related to public safety, public health, or significant public interests;
  3. The information is directly related to a criminal investigation, prosecution, trial, or enforcement of a judgment;
  4. There is sufficient evidence that the request involves malicious intent or an abuse of rights;
  5. Responding to the request would seriously harm your lawful rights and interests or those of another individual or organization;
  6. The information involves trade secrets;
  7. Retention is required to comply with a legal obligation; or
  8. Other circumstances provided by applicable laws and regulations.

6. How We Respond to Your Requests

You may disable relevant device permissions through the settings function of your mobile device.

You may also view or manage certain personal information through the personal center of the Product.

You may click “My” – “Contact Customer Service” to submit requests relating to:

To protect the security of your account and personal information, we may require you to submit a written request or provide information necessary to verify your identity before processing your request.

We will normally respond within fifteen working days or within another period required by applicable law.

If you are not satisfied with our response, you may submit a complaint by contacting customer service.

VI. How We Handle Children’s Personal Information

Our products, websites, and services are primarily intended for adults.

CC Information Technology Co., Limited and ZAI Creative LLC attach importance to the protection of the personal information of children and minors.

If you are under the age of 18, you should read and agree to this Privacy Policy under the supervision and guidance of your parent or other legal guardian before using the relevant services of the Product.

You should use our services or provide personal information only after obtaining the consent of your parent or legal guardian where required by applicable law.

Where we collect personal information relating to a minor through the use of our products or services with the consent of a parent or guardian, we will only use, share, transfer, or disclose such information:

If we discover that we have collected personal information from a minor without obtaining verifiable parental or guardian consent where such consent is required, we will take reasonable steps to delete the information as soon as possible.

Parents or guardians who believe that a minor has provided personal information to us without proper consent may contact us through the contact information provided in this Policy.

VII. How Your Personal Information Is Transferred Globally

Currently, we do not transfer or store your personal information across borders.

If we need to transfer or store your personal information across borders in the future, we will comply with applicable laws and regulations.

Where required, we will inform you of matters such as:

We will obtain your separate consent or complete other required legal procedures before carrying out a cross-border transfer where required by applicable law.

VIII. How This Policy Will Be Updated

We may update this Privacy Policy from time to time to reflect changes in our services, processing activities, business operations, technologies, or applicable legal requirements.

After this Privacy Policy is updated, we may display the updated Privacy Policy and information about material changes through:

We will process personal information in accordance with the rules for collection and use disclosed in the applicable version of this Privacy Policy.

If the purpose or method of processing personal information materially changes, we will obtain your consent again where required by applicable law.

Where applicable law permits processing without consent, we may process personal information on another lawful basis.

Your continued use of our services after an updated Privacy Policy becomes effective may indicate your acknowledgment of the updated Policy, to the extent permitted by applicable law.

Where applicable law requires express consent, we will separately obtain such consent.

IX. Application of This Policy

This Policy applies to all services provided through the Product by CC Information Technology Co., Limited and ZAI Creative LLC, unless another privacy policy or separate notice expressly applies to a particular product or service.

When you log in to or use the Product for the first time, we may prompt you to read this Policy and obtain your consent where required by applicable law.

Unless otherwise agreed or provided by law, this Privacy Policy does not apply to products, websites, or services independently provided by third parties that are linked to or integrated with the Product.

Your use of third-party services, including any personal information you provide directly to a third party, will be governed by the terms of service and privacy policy of that third party rather than this Privacy Policy.

Please carefully read the terms and privacy policies of the relevant third parties.

You should protect your personal information and provide it to a third party only when necessary.

X. Contact Us

If you have any questions, comments, requests, complaints, or suggestions regarding the use of our products or services or this Privacy Policy, you may contact us using the following information:

Operating, Service, and Copyright Entities:

CC Information Technology Co., Limited and ZAI Creative LLC

Registered Address of ZAI Creative LLC:

30 N Gould St., Sheridan, WY 81801, United States

Customer Service Email:

ichannelchc@gmail.com

We will review your request and respond within the period required by applicable law.

Effective Date

This Privacy Policy was issued and became effective on:

January 15, 2024