Introduction

Written (Written Inc, address: RAK DAO, Ras Al Khaimah, United Arab Emirates) ("Written," "we," "us," "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our blockchain-based digital book marketplace and reading platform, including our website, mobile applications, and related services (collectively, the "Service"). This Privacy Policy should be read together with our Cookie Policy, which provides detailed information about how we use cookies and similar technologies.

Written Does Not Sell Your Personal Information: We want to be clear that we do not sell, rent, or trade your personal information to any third parties for commercial or marketing purposes. Your privacy is fundamental to our service, and we are committed to maintaining the trust you place in us.

A note about blockchain technology: Written's Service utilizes blockchain technology to facilitate transactions and maintain records of digital book ownership. Due to the immutable nature of blockchain technology, certain information stored on the blockchain cannot be modified or deleted once recorded. You acknowledge and understand that any information stored on the blockchain will remain there permanently, and we will not be able to modify or remove it.

Please read this Privacy Policy carefully. By accessing or using the Service, you provide your explicit consent to the collection, use, and sharing of your information as described herein. You may withdraw this consent at any time; however, as the processing of your personal information is essential to providing the Service, withdrawing consent will result in the termination of your access to the Service. If you do not agree with our policies and practices or do not consent to the processing of your personal information as described herein, please do not use our Service.

Table of Contents

1. Types of Users and Information We Collect
2. How We Collect Information
3. Legal Basis for Processing
4. Third-Party Services and Data Processing
5. How We Use Your Information
6. Information on Blockchain Networks
7. How We Share Your Information
8. Your Privacy Rights and Choices
9. Data Security
10. International Data Transfers
11. Children's Privacy
12. Changes to This Privacy Policy
13. Contact Information

1. Types of Users and Information We Collect

User Categories

• Readers: Individuals who register to purchase, read, and resell digital books
• Authors: Content creators who publish and sell digital books through the platform
• Visitors: Individuals who browse our website without registering

Information We Collect

Account and Profile Information

• Name and surname (optional for Readers and necessary for Authors)
• Email address
• Username/nickname (optional)
• Password (encrypted)
• Profile picture (optional)
• Phone number (optional)
• Billing and shipping addresses
• Non-custodial cryptocurrency wallet address
• Links to social networks (optional)
• User-generated content (UGC) for both Readers and Authors, which may include:
  • Profile descriptions
  • Author biographies
  • Custom collection descriptions
  • User reviews and ratings
  • Other optional profile information as made available through the Service

Transaction and Blockchain Information

• Purchase and resale history
• Books owned and previously owned
• Published books (for Authors)
• Transaction timestamps for both purchases and resales
• Payment information
• Smart contract interactions including resale listings
• Secondary market activity
• Resale pricing history
• Blockchain transaction records
• Royalty distribution records
• Correlation between public blockchain addresses and user email addresses
• Transaction patterns and history
• Wallet addresses associated with transactions

Content Information (Authors)

• Published books and associated metadata
• Book pricing and availability settings
• Sales history
• Royalty earnings
• Marketing preferences
• Bank account or cryptocurrency wallet information for payments

Service Usage Information

• Reading activity data including:
  • Book opening and closing times
  • Page navigation patterns
  • Screenshot attempts
  • External display usage
  • Reading session duration
  • Progress tracking
• Device type and settings used for reading
  • Email engagement metrics, including:
  • Email opens
  • Click-through rates
  • Interaction times
  • Email client information
• Reading progress and history
• Bookmarks and annotations
• Favorite books and authors
• Reading preferences
• Device information
• Time zone and language preferences
• IP addresses (for security, fraud prevention, and geographic optimization)

Technical Information

• IP address
• Browser type and version
• Operating system
• Device identifiers
• Access timestamps
• Page views and navigation
• App usage statistics
• Error logs
• Browser cookies
• Mobile application tokens
• Authentication tokens
• Session data

2. How We Collect Information

Direct Collection

• Information you provide when creating an account
• Information you submit when publishing books
• Transaction data you generate through the Service
• Communications with our support team

Automated Collection

• Cookies and similar tracking technologies (see our detailed Cookie Policy)
• Server logs
• Analytics tools
• Mobile app usage data
• Blockchain network interactions

For detailed information about the cookies we use, their purposes, and your choices regarding cookies, please visit our Cookie Policy.

Third-Party Sources

• Identity verification services
• Payment processors
• Blockchain analytics providers
• Public blockchain data

Legal Basis for Processing

Written relies on your explicit consent as the primary legal basis for processing your personal information. This means:

Consent-Based Processing

• We will only collect and process your personal information after obtaining your explicit consent
• Your consent is obtained through clear affirmative actions(such as checking box)
• You can withdraw your consent at any time
• We will ask for separate consent for different processing activities
• Consent requests are presented in clear and plain language

Consent Management

• You can modify or withdraw your consent at any time through your account settings
• Withdrawing consent will not affect the lawfulness of processing based on consent before withdrawal
• If you withdraw consent, we will have to terminate your access to the Service as we cannot provide our services without processing your personal data
• Upon consent withdrawal, your account will be deactivated and you will no longer be able to:
  • Access your digital book collection
  • Participate in the marketplace
  • Use the reading applications
  • Conduct any transactions
  • Note: Blockchain records of your previous transactions will remain immutable and publicly visible
• We maintain records of all consent given and withdrawn

Exceptions to Consent-Based Processing

We may process your information without consent only when:

• Required by law
• Necessary to fulfill legal obligations
• Required to protect vital interests
• Ordered by court or regulatory authority

Third-Party Services and Data Processing

Authentication and Wallet Services

• Magic.link
  • Purpose: User authentication and wallet management
  • Data processed: Email addresses, authentication tokens
  • Privacy Policy: https://magic.link/legal/privacy-policy
  • Data retention: Duration of service use

Payment Processing

• Coinflow
  • Purpose: Payment processing and transaction management
  • Data processed: Payment information, transaction details
  • Privacy Policy: Coinflow Privacy Policy
  • Data retention: As required by financial regulations

Insurance Services

• nsure.ai
  • Purpose: Transaction insurance
  • Data processed: Transaction details, risk assessment data
  • Privacy Policy: nsure.ai Privacy Policy
  • Data retention: As specified in their privacy policy

5. How We Use Your Information

We use your information for the following purposes:

Essential Service Operations

• Processing payments and distributing royalties from both initial sales and resales
• Managing digital book access and ownership transfers
• Operating the secondary market for digital books
• Validating ownership rights and transfer eligibility
• Providing customer support
• Ensuring platform security
• Preventing fraud and abuse in both primary and secondary markets
• Facilitating book purchases, sales, and resales

Service Improvement

• Analyzing usage patterns
• Improving user experience
• Developing new features
• Fixing technical issues
• Conducting research and analytics

Communication

• Sending transaction confirmations
• Providing service updates
• Responding to support requests
• Marketing communications (with consent)
• Author notifications about sales and activity

Legal and Compliance

• Enforcing our Terms of Service
• Complying with legal obligations
• Responding to legal requests
• Protecting our rights and interests

6.Information on Blockchain Networks

The following information is stored permanently on the blockchain:

Public Information

• Wallet addresses
• Transaction history
• Book ownership records
• Smart contract interactions
• Public profile information
• Published book metadata

Protected Information

• Encrypted content access keys
• Rights management data
• Author royalty arrangements
• Please note that due to the nature of blockchain technology, this information cannot be deleted or modified once recorded.

7. How We Share Your Information

Our Commitment to Not Selling Your Data

We do not and will not sell your personal information to third parties. While we do share certain information as described below to operate our service effectively, we never sell, rent, or trade your personal information for monetary or other consideration. This includes not selling your:

• Contact information
• Reading habits and preferences
• Collection data
• Transaction history
• Usage patterns
• Any other personal information

Service Providers

• Cloud hosting providers
• Payment processors
• Analytics services
• Customer support tools
• Identity verification services

Business Partners

• Authors (for purchased books)
• Marketing partners (with consent)
• Integration partners
• API service providers

Legal Requirements

• Court orders
• Legal investigations
• Regulatory compliance
• Fraud prevention
• Protection of rights

Business Transfers

• Mergers and acquisitions
• Asset sales
• Restructuring
• Bankruptcy proceedings

8. Your Privacy Rights and Choices

Access and Control

• View and update account information
• Download your data
• Request data deletion (where possible)
• Opt-out of marketing (if consent was given by you previously)
• Manage cookie preferences (see our Cookie Policy)
• Control tracking technologies

GDPR Rights (EU/UK Residents)

• Right to withdraw consent for processing of personal information in full at any time (please note that this will result in service termination)
  • If you withdraw your consent to receive marketing emails, your access to the Service will continue without interruption, but we will stop sending you marketing emails.
• Right to access your personal data
• Right to rectification of inaccurate data
• Right to erasure (where possible)
• Right to restrict processing
• Right to data portability
• Right to object to processing
• Right to lodge a complaint with a supervisory authority

When you exercise your right to withdraw consent:

• Your access to the Service will be terminated
• Your account will be deactivated
• Your data will be deleted except where required by law or technical limitations (such as blockchain records)
• You will be provided with a copy of your data if requested
• You will receive confirmation of account termination
• All automated processing of your data will cease
• Blockchain records of your previous transactions will remain public and immutable
• You can provide new consent at any time to create a new account

CCPA Rights (California Residents)

• Right to know what personal information is collected, used, shared, or sold
• Right to delete personal information held by businesses
• Right to opt-out of sale of personal information (Note: Written does not sell personal information under any circumstances)

Account Deletion

You may request account deletion at any time. However, please note:

• Blockchain records cannot be deleted
• Some information may be retained for legal purposes
• Backup copies may exist temporarily
• Shared information may remain visible

9. Data Security

We implement appropriate technical and organizational measures to protect your information, including:

• Encryption of personal data
• Secure communication protocols
• Access controls
• Regular security assessments
• Employee training
• Incident response procedures
• Backup systems
• Monitoring and logging

However, no security system is impenetrable. We cannot guarantee the security of your information or that unauthorized access will never occur.

10. International Data Transfers

We operate globally and may transfer your information to countries other than your own. We ensure appropriate safeguards are in place through:

• Standard contractual clauses
• Privacy Shield certification (where applicable)
• Data processing agreements
• Security assessments
• Legal compliance reviews

11. Children's Privacy

• Service is not intended for users under 18
• We do not knowingly collect data from children
• We will delete any identified child's data
• Parents can contact us about their child's data
• Age verification may be required

12. Changes to This Privacy Policy

We may update this Privacy Policy periodically. We will notify you of material changes through:

• Email notifications
• Service announcements
• Website notices
• App notifications

Continued use of the Service after changes constitutes acceptance of the updated Policy.

13. Contact Information

For privacy-related questions or requests:

Email: [email protected]

Written Inc, address: RAK DAO, Ras Al Khaimah, United Arab Emirates