Privacy Policy

Version: v1.1
Effective date: 2026-11-03
Last updated: 2026-11-03
Revision history: v0.4 → v0.5 (2026-09-03, added the Section 6.1 disclosure "Analytics on affiliated websites"); v0.5 → v0.6 (2026-09-15, third-party sign-in options updated to Google / Apple / Discord; MINOR revision, no renewed consent required); v0.6 → v0.7 (2026-09-15, marketing consent in Section 5 changed to a box that is ticked by default on the sign-in page and can be unticked before signing in; applies only to those who complete sign-in with the box ticked from then on, does not affect those who have withdrawn, MINOR); v0.7 → v0.8 (2026-09-28, added "building Meta advertising audiences with hashed email addresses" as a use under marketing consent and added Meta and Zapier as processors; as this is a new purpose of use, it applies only to marketing consent obtained from this version onwards and does not apply retroactively to earlier consent, and no bulk upload is made); v0.8 → v0.9 (2026-09-28, added Section 6.2 "Signing in through Partner Brands": connection of external Partner Brands, the consent screen, and a member number unique to each brand; data is provided to a brand only when you press "Agree" on the consent screen, existing users are not affected, MINOR); v0.9 → v0.10 (2026-10-01, clarification to Section 5: the "Also subscribe to 老喬報" checkbox appears only in the Chinese interface, and interfaces in other languages offer no subscription option because the newsletter is published in Traditional Chinese; signing in through a non-Chinese interface never subscribes you, and existing subscribers are not affected or unsubscribed, MINOR); v0.10 → v1.0 (2026-10-31, official version: contact email changed to service@joelin.cc; no EU representative designated; the rights in Section 9 apply to all users and response time limits are stated, with new Section 9.5 for US residents and Section 9.6 for other countries or regions; Section 10 states that the Service is not directed at children under 13; former "to be confirmed" items resolved; the same set of regional supplements as the joelin.cc network privacy policy is used. No items of data collected or purposes of use were added, MINOR, no renewed consent required); v1.0 → v1.1 (2026-11-03, Section 6.1 rewritten: the Service's server now sends account events directly to Google Analytics 4 at three points (when an account is created, when you sign in to an affiliated website, and when an account is deleted), carrying only the anonymous analytics ID, the analytics client ID and session ID already in your browser, the sign-in method, the site name and the country / region, and not your email address or raw account identifier; also states plainly that the network currently provides no cookie consent banner; Sections 3.2, 4, 6 and 9.5 updated accordingly, with the Section 4 purpose codes aligned with the Personal Data Collection Notice; as this is a new purpose of use, it applies only to events occurring on or after this version's effective date, and earlier records are not sent retroactively)

This document is an English translation of the Chinese (Traditional) version. In the event of any discrepancy, the Chinese version prevails.

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1. Introduction and Scope

This Privacy Policy explains how 話圈圈股份有限公司 (Blobpot Co., Ltd., Taiwan, Tax ID 85082592; brand: joelin.cc) ("we" or "us") collects, processes and uses your personal data through the member identity hub id.joelin.cc (the "Service").

The Service is a centralized identity verification service (Identity Provider) that lets you sign in with a single identity to the services we operate and, with your consent, to the services of brands that partner with us (see Section 6.2). Sign-in is currently available with a Google account, an Apple account, a Discord account and an email sign-in link / verification code; if other sign-in methods are added in the future, this Policy will apply to them equally.

We also comply with:

• the Personal Data Protection Act of Taiwan (Republic of China) and its Enforcement Rules;
• the EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) — applicable when the Service is offered to users in the European Union; the UK GDPR and the Swiss Federal Act on Data Protection are applied in the same way;
• the disclosure requirements that US state privacy laws impose on website operators (see Section 9.5).

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2. Who We Are (Data Controller)

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3. What Personal Data We Collect

3.1 Data you provide

• Email address: the email address you enter when signing in with a Magic Link; it is required for sign-in.
• Marketing consent status: whether you ticked the box to receive marketing information (optional), and the timestamp at the time of ticking.
• Third-party sign-in data: when you choose to sign in with a Google, Apple or Discord account, basic identifying information provided by that service with your authorization, such as your email address, name / nickname and profile picture (with Apple you may choose "Hide My Email", in which case we receive the relay address provided by Apple).
• (Future) Mobile phone number: if mobile phone number verification is introduced in the future, we will update this Policy and inform you before that feature launches.

3.2 Data collected automatically by the system

• timestamps of sign-ins and visits, and sign-in records;
• the IP address of your connection, device and browser information, and language preference;
• authorization and binding identifiers (binding_id) generated when you sign in to each Connected Service, and related records.
• the Google Analytics client ID and session ID in your browser that are shared across the network (analytics cookies set by Cloudflare Zaraz; the Service reads them only for the account event statistics described in Section 6.1);
• records of your consent when you agree to sign in to a Partner Brand (which brand, which data scope, and when), and the member number we generate for that brand (see Section 6.2).

3.3 Data we do not collect

The Service is only an identity hub and does not collect or store business content (such as order details, photos, products or amounts). Such data is kept by each business in its own systems, and the Service does not access it. The Service also does not use passwords, so it does not store any passwords.

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4. Purposes of Collection, Categories of Personal Data and Legal Bases

Specific purpose codes under Taiwan's Personal Data Protection Act (per the Ministry of Justice list “Specific Purposes and Categories of Personal Data under the Personal Data Protection Act”; the same list as Article 2 of the "Personal Data Collection Notice"): 040 marketing; 069 contracts, quasi-contracts and other legal relationships; 090 consumer and customer management and services; 135 information (communication) services; 136 information (communication) and database management; 137 information and communication security and management; 157 investigation, statistics and research analysis.
Categories of personal data: C001 personal identifiers (email); connection identifiers and internet usage records (IP, device information, analytics client ID).

For the "notice at the time of collection" required by Article 8 of Taiwan's Personal Data Protection Act, see also the "Personal Data Collection Notice" (pdpa-collection-notice.md, provided via a link on the sign-in page).

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5. Marketing Consent (Optional)

• Receiving marketing information is optional. The "Also subscribe to 老喬報" checkbox on the sign-in page is ticked by default, and you may untick it before pressing any sign-in button; completing sign-in with the box ticked is deemed consent to receive marketing information (under Article 20 of the Personal Data Protection Act, we provide a free means of unsubscribing in every marketing email). Anyone who has expressly withdrawn consent will not be added again by signing in again. This checkbox is displayed only in the Chinese interface; interfaces in other languages offer no subscription option (the newsletter is published in Traditional Chinese), and signing in through these interfaces does not subscribe you; existing subscribers who sign in through these interfaces keep their subscription status unchanged.
• Marketing consent is independent of your use of the services: not ticking the box does not affect your ability to sign in or use any service.
• We record when you consented and the policy version in effect at the time of consent as evidence that consent was lawfully obtained; on withdrawal, we keep the original consent record and separately record the time of withdrawal (for how this is recorded, see the engineering specification consent-versioning-spec.md).
• You may withdraw your marketing consent at any time (see Article 9); withdrawal does not affect processing lawfully carried out before withdrawal, nor your ability to continue signing in and using the services.
• Marketing consent obtained on or after September 28, 2026 also covers building Meta (Facebook, Instagram) advertising audiences with your email address: your email address is uploaded and matched in hashed (one-way encrypted) form, to avoid repeatedly showing subscription ads to existing subscribers or to find readers with similar interests. Once you withdraw marketing consent (including by unsubscribing from an email), it will no longer be used to build audiences; if you want data already uploaded to be removed from an audience, please email service@joelin.cc and we will handle it within 30 days of receipt. Marketing consent obtained before that date does not cover this use.
• Marketing consent means subscribing to the "老喬報" newsletter (a Traditional Chinese newsletter); the consent status in the Service is synchronized in both directions with the newsletter delivery system (Moosend): ticking / unticking the box in the Service updates your subscription status in Moosend, and clicking the unsubscribe link in a newsletter email is also synchronized back to the Service and treated as withdrawal of consent.

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6. Sharing of Personal Data and Processors

We do not sell your personal data. To provide the Service, we engage the following processors (data processors) to process your personal data and require them to provide security protection that complies with the law:

Apart from the processors above, we provide the data listed in Section 6.2 to the Partner Brand you choose to sign in to only when you press "Agree" on the consent screen.

6.1 Analytics on affiliated websites

Account event statistics by the Service (from 2026-11-03): at the three points below, the Service's server sends one event directly to Google Analytics 4 (Google LLC) to count sign-ups, sign-ins and account deletions across the network: (1) when an account is created; (2) when you sign in to an affiliated website and the Service issues the sign-in pass; (3) when an account is deleted. Each event carries only the following data:

• Anonymous analytics ID: an ID derived from a one-way hash of your account identifier, which cannot be reversed to identify your account;
• Analytics client ID and session ID: the Google Analytics client ID and session ID already in your browser (read from the network-wide analytics cookie set by Cloudflare Zaraz), so that the event can be matched with the browsing statistics of the same browser across the network;
• the sign-in method (e.g. email, Google, Apple, Discord) and the name of the affiliated website;
• Country / region: determined by Cloudflare from your connection; the Service does not send your IP address to Google Analytics.

The Service does not send your email address, nor your raw account identifier. The legal basis for this processing is legitimate interests (understanding how the services are used in order to improve them, GDPR Art. 6(1)(f)), and you may exercise your right to object under Section 9. As this is a new purpose of use, it applies only to events occurring on or after 2026-11-03; earlier sign-up, sign-in or account deletion records are not sent retroactively.

Analytics by each affiliated website: affiliated websites that use id.joelin.cc for sign-in (the *.joelin.cc network of sites) may compile usage statistics using an anonymous analytics ID derived from a one-way hash of your account identifier (Google Analytics 4 User-ID); this ID likewise cannot be reversed to identify your account. For details, please see the privacy policy of each affiliated website.

Cookie consent: the network (including the Service) currently does not provide a cookie consent banner; the analytics cookies above are set by Cloudflare Zaraz when each site's pages load, without being conditional on prior consent. You can block or delete cookies through your browser settings.

6.2 Signing in through Partner Brands

Some brands that partner with us ("Partner Brands") let you sign in to their websites or services with your joelin.cc account. It works as follows:

• We ask you first: the first time you sign in from a Partner Brand, we show a consent screen listing the data that brand will receive; data is provided only if you press "Agree", and no data at all is provided if you press "Disagree".
• Data provided: we always provide only one member number unique to that brand. This number is given only to that brand; every other Partner Brand receives a different number, so brands cannot use the numbers to identify the same person across brands; only we can map a number back to your account, and we do not perform cross-brand matching on behalf of Partner Brands. Your email, or your display name and profile picture, are provided as well only if the consent screen additionally lists them.
• Data not provided: your sign-in method, your records in our other services and your marketing consent status are never provided to Partner Brands.
• Responsibilities of Partner Brands: once a Partner Brand receives the data, it acts as an independent personal data collector / controller for its own business, processes the data in accordance with its own privacy policy, and bears the duty to inform you.
• Revoking authorization: you may revoke a Partner Brand's authorization at any time under "Sites" in the account center; after revocation, that brand can no longer use your account to sign you in, and you will be asked again the next time you sign in.
• Deleting your account: when you delete your joelin.cc account, we delete it immediately and notify the Partner Brands you previously agreed to; the notification does not delay your deletion. After deletion, the member numbers held by Partner Brands can no longer be mapped back to anyone. Data that Partner Brands store themselves will, under our agreements with them, be deleted or anonymized by the Partner Brands after they receive the notification.

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7. International Data Transfers

Your personal data is stored in a database in Japan (Tokyo) and may be transmitted through Cloudflare's global network; email services may process your email address in the EU or the United States. In other words, your personal data is transferred outside Taiwan (Republic of China) for processing and storage.

• Taiwan's Personal Data Protection Act: these cross-border transfers are not subject to any restriction imposed by the central competent authority under Article 21 of the Personal Data Protection Act; we have disclosed the transfer destinations and recipients in this Policy and in the collection notice.
• GDPR: your data is collected directly by us; transfers to Japan are made on the basis of the EU's adequacy decision for Japan; other processors provide protection under their data processing terms with us (including the EU Standard Contractual Clauses (SCCs), or the provider's certification under the EU-U.S. Data Privacy Framework).

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8. Retention Period

• Your identity and profile data (email, marketing consent status) is retained for as long as your account exists.
• Sign-in and visit records (including IP and device information) are retained for the period necessary to achieve the purposes of collection, or until the period required by law expires.
• After your account is deleted, we will delete or anonymize your personal data within a reasonable period, except where the law imposes a separate retention obligation.

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9. Your Rights and How to Exercise Them

Wherever you are, we provide the rights listed in 9.1 and 9.2 below to everyone, regardless of whether the law where you are located requires it.

9.1 Article 3 of Taiwan's Personal Data Protection Act

You have the following rights regarding your personal data: to inquire about or request to review it, to request a copy, to request supplementation or correction, to request that collection / processing / use be stopped, and to request deletion.

9.2 EU GDPR (Articles 15–22)

The right of access, the right to rectification, the right to erasure (the right to be forgotten), the right to restriction of processing, the right to data portability, the right to object, the right to withdraw consent, and the right not to be subject to a decision based solely on automated processing.

9.3 How to exercise your rights

Please email service@joelin.cc. We will handle requests to inquire about, review or obtain a copy of your data within 15 days of receipt, and other requests within 30 days; if we need more time, we will tell you why before the deadline. Exercising your rights is free of charge, and we will not treat you differently for doing so. To protect your interests, we may first need to verify your identity (for example, by asking you to confirm by replying from your registered email address).

9.4 Complaints

• Taiwan: you may file a complaint with the competent authority for personal data protection or the competent authority for the relevant industry.
• EU / UK / Switzerland: you may file a complaint with the data protection supervisory authority (Supervisory Authority) where you live, where you work or where the alleged infringement took place; in the UK this is the Information Commissioner's Office (ICO), and in Switzerland the Federal Data Protection and Information Commissioner (FDPIC).

9.5 US Residents

• Categories we collect (using the categories commonly used in US state laws): identifiers (email address, hashed email address, account identifiers, hashed anonymous analytics ID, analytics client ID, IP address); internet activity information (sign-in and visit records, device and browser information). We do not collect sensitive personal information (such as precise geolocation, health information, financial accounts or government identification numbers). For sources, purposes, recipients and retention periods, see Sections 3, 4, 6 and 8.
• Selling and sharing: we do not sell your personal data for money. For those who gave marketing consent on or after September 28, 2026, we build advertising audiences on Meta with hashed email addresses (see Section 5); some state laws may treat this as "sharing" or "targeted advertising". You may withdraw your marketing consent (including by unsubscribing in a newsletter email), or email us to ask that we stop using your data for this purpose, and we will handle the request within 15 business days.
• Do Not Track: the network (including the Service) loads Google Analytics 4 through Cloudflare Zaraz, which sets analytics cookies, and Google's advertising audience (remarketing) features are enabled (see Section 6.1); the Service itself does not place any additional advertising cookies; there is currently no uniform industry standard for the browser "Do Not Track" signal, and the Service does not change how it handles data when it receives that signal.
• Appeals: if we decline your request, you may reply to the same email to ask for a review, and we will reply with the outcome and our reasons within 45 days; if you still disagree, you may complain to the Attorney General of your state.
• California residents: we do not provide your personal data to third parties for their own direct marketing purposes.
• The above applies to all US residents, regardless of whether we meet the applicability thresholds of each state's laws.

9.6 Other Countries or Regions

If the law where you are located gives you more protection than this Policy, we will follow that law; please contact us through the channel in Section 9.3.

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10. Children and Minors

The Service is not directed at children under 13. We do not knowingly collect their personal data, and we do not sell or share the personal data of users under 16. If you find that a child has provided us with personal data, please contact us and we will delete it after confirmation.

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11. Security Measures

We take the following measures to protect your personal data: HTTPS encryption for all transmissions, passwordless sign-in (reducing the risk of credential leaks), database row-level access control (Row-Level Security), the principle of data minimization, separate safekeeping of signing keys, short expiry times for sign-in links, and abuse prevention mechanisms such as sign-in rate limits.

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12. Changes to This Policy

When this Policy is revised, we will update the version number and "Last updated" date on this page and keep past versions available for reference. For material changes (such as adding items of data collected, adding purposes of use, or changing processors in a way that affects your rights), we will notify you by email, an announcement on the sign-in page or other appropriate means; for processing based on "consent" (such as marketing), we will ask for your consent again where necessary (for the versioning mechanism, see consent-versioning-spec.md).

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13. Contact Us

If you have any questions about this Policy or your personal data, please email service@joelin.cc.