Privacy Notice

1. Who We Are

This Privacy Notice explains how your personal data is collected, used, shared and protected when you use the TRManga (TRwebtoon) service available at trmanga.com (the "Service").

The data controller responsible for your personal data is Moteze Software, LLC, a limited liability company organized under the laws of the State of Delaware, USA ("Company", "we", "us"). You can contact us at [email protected] with any privacy questions or requests.

2. Scope

This notice applies to everyone who visits our website, creates an account, posts content, applies to join a translation team, contacts us, or purchases a Paid Product (Premium, Crystals). Third-party websites linked from the Service are governed by their own privacy policies.

3. Data We Collect

3.1 Information you provide to us

• Account data: full name, username, email address and password (stored only in irreversibly hashed form).
• Profile data: profile picture, cover and frame selection, bio, social media links and your profile privacy preferences.
• User Content: comments, reviews, ratings, votes, reading lists, poll answers, reports and support conversations with our team.
• Translation team and uploader data: information and files you share in team applications, and the series and chapters you upload.
• Contact data: messages you send us through the contact form or by email, and your email address.
• Purchase data: the product you bought, amount, date, order number, and the cardholder name we ask for in order to issue an invoice. We never receive your card details such as card number, expiry date or security code; these are processed directly by the payment provider.
• Legal acceptance records: a record that you accepted the Terms of Service, Privacy Notice and Refund Policy at checkout (date of acceptance, document version, order number, IP address and browser information).

3.2 Information collected automatically

• Usage data: series and chapters you read, your reading progress, series you follow, your notifications, EXP and level data, and your Crystal transaction history.
• Device and connection data: IP address, browser type and version, operating system, language setting, referring page, access dates and times, registration and last login time.
• Security data: IP and request logs kept to detect abuse, spam, bot traffic and account takeover attempts.
• Android app: if you use the app, a random device identifier generated by the app at installation, the app version, the device model and session records (from which device and when you signed in); a notification token if you allow notifications; the advertising ID if ads are shown in the app and you consent. Google Play Integrity is used when you register through the app to verify that the device is genuine.
• Browser and phone notifications: if you allow notifications on the site, the notification address (push subscription) and encryption keys your browser generates for this device, a device label (for example "iPhone · Safari") and the time of the last successful delivery.
• Cookies and similar technologies: see the "Cookies" section below.

3.3 Information we receive from third parties

• Transaction information from the payment provider (Paddle or PayTR), such as whether a payment succeeded, the order number and the amount.
• Aggregated statistics that do not directly identify you, and security verification results, from analytics and security services.

4. How We Use Your Data

• To create and manage your account, keep you signed in and provide the Service.
• To save your reading progress, send notifications for series you follow and show you relevant series recommendations.
• To send notifications to your browser and phone if you have allowed them. You can choose which notifications you receive under Settings > Notifications.
• To operate community features such as comments, reviews, lists, messaging and the level system.
• To process your purchases, add Premium and Crystal products to your account, issue invoices and handle refunds and payment disputes.
• To send transactional emails such as account verification, password resets, order and service notifications.
• To respond to support requests, copyright notices and other requests.
• To keep the Service secure; detect and prevent spam, fraud, bot traffic and abuse; and enforce our Terms of Service.
• To understand how the Service is used, measure performance and improve the Service.
• To show advertisements to users who do not have Premium.
• To comply with our legal obligations (tax, accounting, requests from authorities) and to protect our legal rights.

We do not use your personal data to make automated decisions that produce legal or similarly significant effects concerning you.

To prevent abuse, when you sign up or log in we automatically check whether your IP address belongs to a VPN, proxy, Tor exit node or data center. If such a connection is detected, the sign-up or login is refused; you can still continue reading the site. If you believe the detection is wrong, you can contact us through the contact page with the reference code shown on screen and ask for the case to be reviewed by a person.

5. Legal Bases

If you are located in the European Economic Area, the United Kingdom or a country with similar legislation, we process your data on the following legal bases:

• Performance of a contract: to manage your account, provide the Service and process your purchases.
• Legitimate interests: to keep the Service secure, prevent abuse, and analyze and improve the Service. We balance these interests against your rights and freedoms.
• Legal obligation: to keep tax and accounting records and respond to lawful requests from authorities.
• Consent: where required by law, for non-essential cookies and personalized advertising. You can withdraw your consent at any time.

6. Cookies and Similar Technologies

Cookies are small text files stored in your browser. We also use your browser's local storage (localStorage) for similar purposes. The main types we use are:

• Strictly necessary cookies: required for signing in, keeping your session secure, security verification, form security (CSRF) and abuse prevention. The Service cannot work properly without them.
• Functional cookies and local storage: your reading progress, recently read chapters, light/dark theme preference, reader settings and short-lived records that prevent repeated voting.
• Analytics cookies: via Google Analytics and Google Tag Manager, to measure page views and usage statistics in aggregate.
• Measurement and crash reports in the Android app: the app uses Google's Firebase Analytics to collect in-app usage statistics (screens viewed, numeric IDs of the series and chapters opened, session length, app version, device model, operating system and approximate location derived from your IP address) and a random app instance ID generated by the app, and Firebase Crashlytics to collect crash reports (the technical log at the time of the crash, device and version information). If you are signed in, only your numeric account number is attached to these records. Your search text, comments, email address and username are not sent to these services. You can turn off usage statistics in the app under Settings > Privacy > "Send usage statistics"; in the European Economic Area and the United Kingdom no measurement takes place without your consent. Ads in the app are shown with Google AdMob.
• Advertising cookies: via Google AdSense, to show ads to users who do not have Premium and to measure ad performance. Google may use cookies for interest-based advertising. You can turn off personalized ads in Google Ad Settings.

You can delete or block cookies in your browser settings; however, if you block strictly necessary cookies, some features such as signing in may not work. To opt out of Google Analytics you can use the Google Analytics opt-out browser add-on.

7. Who We Share Your Data With

We do not sell your personal data, and we do not rent it to third parties for money or other valuable consideration. We share your data only in the following cases and only as necessary:

• Payment services: Paddle.com (Paddle.com Market Limited and its affiliates) acts as Merchant of Record for purchases made through Paddle and handles payment, taxes, invoicing, fraud screening and refunds; it processes payment data independently under its own privacy policy. PayTR Ödeme ve Elektronik Para Kuruluşu A.Ş. processes payments made through PayTR. Your email address, billing name, order amount and IP address are shared with these providers.
• Infrastructure and security: Cloudflare, Inc. (content delivery network, DDoS protection and Turnstile bot verification), our hosting provider, Google reCAPTCHA (spam protection on the contact form), and our VPN/proxy detection provider (your IP address is shared only during sign-up and login, to check whether it is a VPN or proxy).
• Email delivery: transactional emails are sent through Google (Gmail) infrastructure.
• Notification services: browser and phone notifications are delivered through your browser's push service (Google, Mozilla, Apple or Microsoft). The content of a notification is end-to-end encrypted; these services cannot read it and only process the notification address and delivery time.
• Analytics and advertising: Google LLC (Google Analytics, Google Tag Manager, Google AdSense; in the Android app Firebase Analytics, Firebase Crashlytics and Google AdMob).
• Embedded content: KLIPY and GIPHY for GIF search and YouTube for tutorial videos. When this content is displayed, the respective provider may receive your IP address and browser information. When you search for GIFs, your browser sends the search directly to KLIPY; KLIPY receives your search term, your IP address and an anonymous identifier derived from your account that does not contain your name or email address. KLIPY processes this data under its own privacy policy.
• Other users: your username, profile picture, comments, reviews and public lists may be visible to other users and visitors. You can limit the visibility of some information in your profile privacy settings. There is no private messaging between users; your support conversations with our team are visible only to you and our authorized team.
• Legal requirements: when required by valid legal process, a court order or a request from a competent authority, or when necessary to protect the rights, safety and property of the Company, our users or others.
• Business transfers: in the event of a merger, acquisition, reorganization or sale of assets, provided that your data remains protected in line with this notice.

Our service providers process your data only to provide services to us and under contractual confidentiality obligations.

8. International Data Transfers

The Company is based in the United States and our service providers operate in various countries. Your personal data may therefore be processed outside your country of residence, including in the United States, where data protection laws may differ. For transfers from the European Economic Area, the United Kingdom or Switzerland, we rely on appropriate safeguards such as the Standard Contractual Clauses approved by the European Commission or adequacy decisions.

9. How Long We Keep Your Data

• Account and profile data: for as long as your account is open. You can permanently delete your account in the TRManga Android app (Account > Settings > Delete account); see the Delete your account page for details. On deletion your name, email address, password, profile data, library, custom lists, reading history, notifications, follow and block relationships, app sessions and IP logs are deleted; your username is changed to "user<number>" and the account can no longer be signed in to. To prevent re-registration with the same email address we keep only an irreversible hash of the address, not the address itself.
• User Content: for as long as your account is open or until you or we remove the content. When an account is deleted, your comments, reviews and ratings remain under the name "user<number>" without information that identifies you.
• Payment and Crystal transaction records: for the legally required retention period; after account deletion they are kept without being linked to your identity.
• Purchase, invoice and legal acceptance records: for as long as required by tax and accounting laws and as necessary for possible refunds, payment disputes and legal claims (generally up to 10 years).
• Security and access logs: for as long as needed for security purposes, generally no more than 12 months; logs related to an ongoing abuse or security incident are kept until the incident is resolved.
• VPN/proxy check records: the check result for an IP address is cached for no more than 7 days; records of sign-up and login attempts where a VPN or proxy was detected (IP address, date, account if any, and reference code) are deleted after 90 days.
• Premium reading history: for Premium members, up to the last 100 series and chapters read are stored in the account so they can continue where they left off on any device. This is deleted within 90 days at the latest after the Premium membership ends or the account is deleted. You can clear this list at any time on the Recently Read page. For users without Premium, reading history is kept only in a cookie in their own browser.
• Notification subscriptions: until you turn notifications off, remove the device from your list, sign out, or your browser invalidates the subscription; closed subscriptions are deleted after 90 days. You can turn notifications off at any time under Settings > Notifications or in your browser's site settings.
• Contact messages: for as long as needed to resolve your request, and a reasonable period afterwards.

10. Security

We apply reasonable technical and organizational measures to protect your data, such as encrypted connections (HTTPS), irreversible password hashing, access controls, bot and abuse protection and regular security updates. However, no method of transmission over the internet or of storage is 100% secure. We recommend using a strong and unique password for your account. If a security breach affects your data, we will notify you and the relevant authorities where required by law.

11. Your Rights

Depending on where you are located, you may have the following rights regarding your personal data:

• Access: to know what data we process about you and to obtain a copy.
• Rectification: to have inaccurate or incomplete data corrected. You can update most profile information yourself in your account settings.
• Erasure: to have your data and account deleted.
• Restriction and objection: to object to certain processing, in particular processing based on legitimate interests.
• Data portability: to receive the data you provided to us in a structured, commonly used format.
• Withdrawal of consent: to withdraw your consent at any time for processing based on consent.
• Complaint: to lodge a complaint with the data protection authority in your country.

U.S. residents (e.g. California): under the California Consumer Privacy Act (CCPA/CPRA) and similar state laws, you have the right to know the categories of personal data we collect, their sources, the purposes and the categories of parties we share them with (described in this notice); to access, correct and delete your data; and to limit the use of sensitive personal information. We do not sell personal data for money. Our advertising partner in the app, Google AdMob, may use the advertising ID for interest-based ads under its own policy; you can turn this off in your phone's ad settings (by resetting or deleting the advertising ID). We will not discriminate against you for exercising these rights. Where required by law, we treat a Global Privacy Control (GPC) signal sent by your browser as a valid opt-out request.

How to exercise your rights: write to [email protected] from the email address registered to your account. You can delete your account yourself in the Android app; if you cannot access the app, you can also send an account deletion request this way. We may ask for reasonable information to verify your identity before processing your request. We respond within 30 days at the latest (this may be extended where permitted by law). You may also make a request through an authorized agent; in that case we will ask for proof of the agent's authority.

12. Children's Privacy

The Service is not directed to children under 13, and we do not knowingly collect personal data from children under 13. If we learn that a child under 13 has provided us with personal data, we delete that data and the related account. Parents or guardians who become aware of such a case can contact us at [email protected]. The Service contains no 18+ content; series labeled 16+ are not suitable for users under 16.

13. Changes to This Notice

We may update this Privacy Notice from time to time. The current version is always published on this page and the "Last updated" date is changed. We will announce material changes on the Service or by email before they take effect.

14. Contact

For privacy questions, requests or complaints: