Privacy Policy
LEGAL
Contents
- Who We Are
- Personal Information We Collect
- Purposes — Why We Use Personal Information
- Consent and How to Withdraw It
- Sharing and Disclosure
- Cookies and Analytics
- Cross-Border Transfers
- Security Safeguards
- Retention — How Long We Keep Information
- Automated Processing and the Engaged-Read Metric — Plain Disclosure
- Your Rights and How to Exercise Them
- Children and Minors
- Privacy Incidents and Breach Notification
- Complaints and Recourse
- Changes to This Policy
- Contact
Site: dramaink.net (the “Site”)
Operator: [LEGAL ENTITY NAME] (“DramaInk”, “we”, “us”, “our”)
Mailing address: [MAILING ADDRESS]
Privacy Officer: [PRIVACY OFFICER NAME] — through the Contact page
General contact: through the Contact page
Effective date: [EFFECTIVE DATE]
Version: [VERSION NUMBER]
1. Who We Are
1.1 DramaInk operates dramaink.net, a catalogue and reading platform for episodic dramas: episode recaps and commentary, cast and series information, member lists and ratings, a fanfiction section, a Creator Partner Program, fan artwork, and community features such as the “Vote to Recap” board.
1.2 We are based in Montreal, Quebec, Canada. This Privacy Policy describes how we collect, use, disclose and protect personal information, in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and Quebec’s Act respecting the protection of personal information in the private sector, as modernized by Law 25.
1.3 Person in charge of the protection of personal information (Privacy Officer). Under Law 25, the person exercising the highest authority within our organization is responsible for the protection of personal information; that function has been delegated in writing to: [PRIVACY OFFICER NAME], reachable through the Contact page and at [MAILING ADDRESS]. The title and contact information of our Privacy Officer are published here in accordance with Law 25.
2. Personal Information We Collect
We collect only the personal information needed for the purposes identified in Section 3.
2.1 Account information. When you register: your email address, display name, and password (stored in hashed form — we never store your password in plain text). Optional profile information you choose to add, such as a biography line, avatar image, or preferred language.
2.2 Profile and role information. Your account type and choices, including whether you join as a reader and/or as a creator, and, for creators, the enrolment information needed to participate in the Creator Partner Program.
2.3 User content. Content you publish or submit: fanfiction and stories, recaps, comments, fan artwork files, title requests, and any personal information you choose to include within that content. Content you publish publicly is, by its nature, visible to others. For content you publish, we also record the content-governance information attached to it: whether it was disclosed as AI-assisted, and whether it is tagged “18+” (Mature Content) under the Terms and Conditions.
2.4 Reading activity and engaged-read metrics. Records of your interaction with content: pages viewed, items read, approximate reading time or completion signals, list additions, ratings (1–10), votes and title requests on the “Vote to Recap” board, follows, and similar activity. For creators, these metrics are aggregated into Engaged Read counts used to calculate Creator Partner Program earnings (see Section 10).
2.5 Membership, Tips and payout data. If you purchase a paid membership, send a Tip, or receive creator payouts: transaction records (amount, date, plan or item, status), the last digits or type of payment instrument where the processor shares them, and payout identifiers (such as a payout account reference or email) needed to pay you. Your full payment card number is collected and processed directly by our payment processor (for example, Stripe) and is never received or stored by DramaInk.
2.6 Communications. Messages you send us (support requests, copyright notices, reports, feedback), and our replies. If you report content or another user, we keep a record of the report and its outcome.
2.7 Device, log and cookie data. When you visit the Site: IP address, approximate location derived from IP address (city/country level), browser and device type, operating system, referring pages, pages visited, timestamps, and cookie or similar-technology identifiers (see Section 6). Server logs are generated by our hosting provider as part of normal operation.
2.8 Information from third parties. If you sign in or pay through a third-party service, we receive the information that service confirms to us (for example, that a payment succeeded, or a verified email address), in accordance with that service’s terms and your settings with it.
2.9 What we do not collect. We do not intentionally collect government identification, health information, or other sensitive categories of personal information, and you should not include such information in content you publish. We do not store full payment card numbers (Section 2.5).
3. Purposes — Why We Use Personal Information
We use personal information for the following purposes:
3.1 Providing the Service. Creating and managing your account; displaying catalogue pages, recaps and your published content; operating your personal lists, ratings and reading history features; enabling comments, votes and title requests; and displaying fan artwork after moderation.
3.2 Creator Partner Program. Calculating Engaged Reads and creators’ shares of the membership pool; administering the $25 payout threshold; making payouts; preventing fraud and manipulation of metrics; and producing the earnings displays in creator dashboards.
3.3 Memberships and Tips. Processing paid membership plans, renewals and cancellations; processing Tips to creators; issuing receipts and handling refunds and disputes.
3.4 Safety, moderation and enforcement. Reviewing reported or flagged content and artwork; enforcing our Terms and Conditions; detecting bots, metric manipulation and abuse; and protecting the rights, property and safety of DramaInk, our users and the public. This includes recording and honouring the age confirmation a Member gives before accessing “18+” (Mature) content, and that Member’s mature-content settings, so that restricted content is shown only to Members entitled to see it.
3.5 Communications. Sending service messages (account confirmations, security alerts, billing and payout notices, changes to our terms or policies) and, only with your consent where required, newsletters or promotional emails. You may withdraw consent to marketing emails at any time via the unsubscribe link or your account settings; service messages necessary for your account will still be sent.
3.6 Improvement and analytics. Understanding how the Service is used, in aggregate, to fix problems, plan catalogue and recap priorities (for example, which requested titles to recap), and improve features.
3.7 Legal obligations. Complying with tax, accounting, consumer-protection and other legal requirements; responding to lawful requests; and handling copyright notices and counter-notices.
4. Consent and How to Withdraw It
4.1 Consent. We collect, use and disclose personal information with your consent, except where otherwise permitted or required by law. Consent may be express (for example, when you register, subscribe, or opt in to marketing email) or implied from the circumstances (for example, when you send us a support message, we may use your email address to reply).
4.2 Withdrawing consent. Subject to legal and contractual restrictions and reasonable notice, you may withdraw your consent to our use of your personal information by contacting the Privacy Officer through the Contact page or through your account settings. Withdrawal may mean we can no longer provide some or all of the Service to you (for example, we cannot maintain an account without an email address).
4.3 Closing your account is itself a withdrawal of consent for most ongoing uses; Section 9 describes what we then retain and why.
4.4 Optional information. Where information is optional (for example, a profile biography), you may decline to provide it or remove it at any time without affecting your account.
5. Sharing and Disclosure
5.1 We do not sell personal information. We have not sold, and will not sell, your personal information to third parties.
5.2 Service providers. We share personal information with service providers who process it on our behalf, under contractual or equivalent safeguards, only for the purposes in Section 3, including:
(a) Hosting: Hostinger (website hosting, servers and logs);
(b) Payment processing: payment processors such as Stripe, for memberships, Tips and creator payouts;
(c) Email delivery: our email service provider, for account, billing and (consented) newsletter email;
(d) Analytics and security tools, where used, configured to collect the minimum necessary.
5.3 Public by design. Information you publish publicly — your display name, avatar, published stories, recaps, comments, fan artwork, and public list or rating activity where the Service displays it — is visible to other users and visitors, and may be indexed by search engines. Do not publish personal information you wish to keep private.
5.4 Creators and Tips. When you send a Tip, the receiving creator sees the amount and any display name or message you attach. When you earn as a creator, our payout provider receives the information needed to pay you.
5.5 Legal and safety disclosures. We may disclose personal information where required or permitted by law: to comply with a court order, subpoena or lawful request; to enforce our Terms; to handle copyright notices as described in our Terms and Conditions; or to protect the rights, property or safety of any person.
5.6 Business transactions. If DramaInk is involved in a merger, sale or reorganization, personal information may be transferred as part of that transaction, subject to applicable law (including Law 25’s requirements for such transfers) and to notice to affected users where required.
6. Cookies and Analytics
6.1 Necessary cookies. We use cookies and similar technologies that are strictly necessary for the Service to function: keeping you signed in, remembering security and session state, load balancing, and remembering choices such as language. These cannot be switched off without breaking the Service, and are used without consent where the law permits because they are required to provide a service you requested.
6.2 Optional cookies. Where we use analytics, preference or measurement cookies that are not strictly necessary, we will ask for your consent through a cookie notice or settings control before they are activated, in accordance with Law 25’s requirements (including privacy-protective default settings). You may withdraw that consent at any time through the same control, or block cookies in your browser.
6.3 What analytics see. Analytics data is used in aggregate to understand visits and reading patterns. We do not use cookies to build advertising profiles, and we do not permit third-party advertising trackers on the Service. [If advertising or new analytics tools are introduced, this section will be updated and fresh consent obtained where required.]
6.4 Do Not Track. Because there is no common industry standard for it, we do not currently respond to browser “Do Not Track” signals; our optional-cookie consent control serves this purpose.
7. Cross-Border Transfers
7.1 Where data may be processed. DramaInk is operated from Quebec, Canada, but our service providers may process or store personal information outside Quebec and outside Canada, including in the United States and the European Union (for example, hosting infrastructure, payment processing by Stripe, and email delivery).
7.2 Consequences. Personal information processed in another jurisdiction may be subject to that jurisdiction’s laws and accessible to its courts, law enforcement and national security authorities.
7.3 Safeguards. Before transferring personal information outside Quebec, we carry out the privacy impact assessment required by Law 25 and ensure, by contract or other means, that the information receives protection comparable to that provided under Quebec law. By using the Service, you consent to these transfers as described.
8. Security Safeguards
8.1 We protect personal information with safeguards appropriate to its sensitivity, including: encrypted connections (HTTPS/TLS); hashed password storage; access controls limiting personal information to those who need it for the purposes in Section 3; reputable hosting and payment providers with their own security programs; and keeping software updated.
8.2 No system is perfectly secure. We cannot guarantee absolute security, but we work to protect your information and to respond promptly to incidents (see Section 13).
8.3 Your role. Choose a strong, unique password, keep it confidential, and notify us through the Contact page if you suspect unauthorized access to your account.
9. Retention — How Long We Keep Information
We keep personal information only as long as necessary for the purposes in Section 3 and to meet legal requirements. Indicative periods:
9.1 Account information: while your account is open. On closure, account identifiers are deleted or anonymized within [NUMBER, e.g., 90] days, except as set out below.
9.2 Published content: content you published remains while your account is open. On closure, published content is removed or anonymized (attributed to a generic former-member label) within a reasonable period, except copies in backups, which are cycled out within [NUMBER] days, and content that must be retained for legal reasons.
9.3 Reading activity and Engaged Read metrics: identified activity is retained while the account is open; aggregated, de-identified statistics may be retained indefinitely because they no longer identify you.
9.4 Financial records: membership, Tip, payout and tax records are retained for the period required by Canadian and Quebec tax and bookkeeping law (generally six years from the end of the relevant tax year), even if the account is closed.
9.5 Communications and reports: support messages, copyright notices and moderation records are retained for [NUMBER, e.g., 2 years] after resolution, or longer if needed for legal claims or repeat-infringer records.
9.6 Server logs: retained by our hosting provider for a short operational period (ordinarily up to [NUMBER] days), unless needed to investigate an incident.
9.7 When retention ends, information is securely deleted or anonymized.
10. Automated Processing and the Engaged-Read Metric — Plain Disclosure
10.1 What is automated. The Service automatically records reading activity and computes Engaged Read metrics (Section 2.4). Creator earnings shares are calculated from these metrics automatically, using the formula described in the Terms and Conditions. Content ranking, recommendation and “popular” displays may likewise be generated automatically from activity data.
10.2 What this is not. We do not use automated processing to make decisions that produce legal or similarly significant effects about you outside the Service (such as credit, employment or insurance decisions). The main consequence of the metric for a creator is the size of their share of the Creator Partner Program pool; for a reader, it affects internal rankings and aggregate statistics.
10.3 Anti-fraud filters. Automated filters may exclude reads that appear automated, self-generated or otherwise invalid. If you are a creator and believe your metrics were wrongly excluded, you may contact us and request human review (Section 11).
10.4 No sale of profiles. We do not sell profiles, and we do not profile users for third-party advertising.
10.5 No AI training on your content. We do not use the stories, recaps, artwork or other content you publish on the Service to train artificial-intelligence models, and we do not provide that content to third parties for AI training. If this ever changes, it will be announced in advance and applied only with the consent the law requires.
11. Your Rights and How to Exercise Them
11.1 Under PIPEDA and Quebec’s private-sector privacy legislation (as amended by Law 25), you have the following rights regarding your personal information:
(a) Access: to request access to the personal information we hold about you, and information about how it has been used and disclosed;
(b) Correction / rectification: to request correction of information that is inaccurate, incomplete or ambiguous, or that was collected in contravention of the law;
(c) Deletion: to request deletion of information that is no longer necessary or that was collected unlawfully, subject to legal retention requirements (Section 9);
(d) Withdrawal of consent: as described in Section 4.2;
(e) Portability: to request, in a structured, commonly used technological format, the computerized personal information you provided to us, or its transfer to another organization where technically feasible, as provided by Law 25;
(f) Objection / cessation of dissemination: to request that we stop disseminating your personal information, or de-index links to it, in the circumstances provided by Law 25 (for example, where dissemination contravenes the law or a court order, or causes serious injury to your reputation or privacy);
(g) Automated decisions: to be informed of decisions based exclusively on automated processing and to request human review, as described in Section 10.3 (the Engaged-Read metric involves aggregation rather than exclusively automated decisions about individuals, but we offer review as described).
11.2 How to make a request. Contact our Privacy Officer: [PRIVACY OFFICER NAME], through the Contact page, or [MAILING ADDRESS]. Many requests (access to your profile data, corrections to your profile, deletion of content) can also be made directly in your account settings.
11.3 Identity verification. We may ask you to verify your identity before fulfilling a request, to protect your information from unauthorized disclosure.
11.4 Timelines. We respond to access and rectification requests within 30 days of receipt, as required by Law 25 and PIPEDA, or within any shorter applicable period. If we need more time as permitted by law, we will tell you within the initial period and explain why. Requests are handled free of charge, except where the law permits a minimal fee, of which we would inform you in advance.
11.5 Refusals. If we refuse a request in whole or in part, we will explain the reasons and inform you of your recourse to the Commission d’accès à l’information (Section 14).
11.6 No discrimination. Exercising your privacy rights will not affect the price or quality of the Service we offer you, except where the information is necessary to provide a feature (Section 4.2).
12. Children and Minors
12.1 The Service’s accounts are intended for users 13 years of age and older. Paid memberships, Tips and creator payouts require the age of majority (Section 3 of the Terms and Conditions).
12.2 Under Law 25, consent to the collection of personal information of a minor under 14 years of age must be given by the person having parental authority or the minor’s tutor; for minors 14 and older, consent may be given by the minor or the holder of parental authority. Where our registration flow establishes age, we apply these rules; parents or tutors who believe a child under 14 has provided information without proper consent should contact the Privacy Officer, and we will delete it.
12.3 We do not knowingly market paid features to minors, and creators publishing content must respect the content rules in the Terms and Conditions, including the absolute prohibition on sexualization of minors.
12.4 Age-restricted content. Content tagged “18+” (Mature Content) under the Terms and Conditions is shown only to signed-in Members whose account records an age confirmation that they are at least 18 years old (or the age of majority where they live, if higher). The confirmation, and the Member’s mature-content display settings, are kept with the account for as long as they are needed to enforce the restriction, and are removed on account closure in accordance with Section 9.
13. Privacy Incidents and Breach Notification
13.1 Our commitment. If we become aware of a confidentiality incident involving personal information (unauthorized access, use, disclosure, or loss), we will act promptly to contain it, assess the risk of serious injury, and reduce harm.
13.2 Notification — Quebec. Where an incident presents a risk of serious injury, we will notify the Commission d’accès à l’information du Québec and the affected individuals, as required by Law 25, and we will keep a register of incidents as the law requires.
13.3 Notification — federal. Where PIPEDA applies and there has been a breach of security safeguards involving personal information under our control posing a real risk of significant harm, we will report to the Office of the Privacy Commissioner of Canada and notify affected individuals as PIPEDA requires, and maintain breach records for at least 24 months.
13.4 What notices contain. Notifications will describe, as available: what happened, the information involved, the steps we have taken, and what affected individuals can do to protect themselves.
14. Complaints and Recourse
14.1 Talk to us first. Most concerns can be resolved quickly by our Privacy Officer: [PRIVACY OFFICER NAME] — through the Contact page.
14.2 Commission d’accès à l’information (CAI) — Quebec. You may file a complaint with the Commission d’accès à l’information du Québec, the oversight body for Quebec’s private-sector privacy legislation: [CAI WEBSITE / ADDRESS — to be completed at publication].
14.3 Office of the Privacy Commissioner of Canada (OPC). You may also complain to the Office of the Privacy Commissioner of Canada, which oversees PIPEDA: [OPC WEBSITE / ADDRESS — to be completed at publication].
14.4 Contacting a regulator does not affect your other legal recourses, and we will cooperate with any investigation.
15. Changes to This Policy
15.1 We may update this Privacy Policy from time to time to reflect changes in the Service, our practices, or the law.
15.2 Notice. Material changes will be announced by email to account holders and/or by a prominent notice on the Site at least [NUMBER] days before they take effect, or such period as applicable law requires. Where a change requires fresh consent (for example, a new use of personal information), we will obtain it before applying the change to you.
15.3 Version history. The version number and effective date appear at the top of this Policy. Prior versions are available on request from the Privacy Officer.
16. Contact
Questions, requests or complaints about personal information:
Privacy Officer: [PRIVACY OFFICER NAME]
Contact: through the Contact page
Mail: [LEGAL ENTITY NAME], [MAILING ADDRESS]
End of Privacy Policy.
See also: our Terms & Conditions.
