Privacy Policy

Operator Information

This site is operated in Taiwan by Penchan (小企鵝 Penchan), an individual, who is the controller of personal data collected through this site. For privacy questions, or if you need the operator's legal name to exercise your rights, contact [email protected].

Data We Collect

Except when you voluntarily subscribe to the newsletter, contact this site, or submit information through a form, this site does not proactively collect your name, email address, or other information that can directly identify you. Through the following services, this site processes technical data needed for the connection (such as IP address and browser information), analytics data after your consent, anonymous usage counts, and data you submit:

Google Analytics 4 (GA4)

After you select "Got it", this site uses GA4 to analyze website traffic. GA4 is loaded through the Google tag (gtag.js, main-site pages) and through Cloudflare Zaraz (all pages including /cards, forwarded to Google by Cloudflare's servers). GA4 may collect:

• IP address, used to estimate approximate location; Google states that GA4 does not log or store IP addresses
• Browser type, operating system, device type, screen size, and language
• URLs of pages viewed (including on-site search terms), time on page, and traffic source
• Geographic location at country or region level, not precise location
• A random visitor identifier stored in a cookie, used to tell visitors and sessions apart

This site currently does not enable Google Signals, Google Ads linking, remarketing, or ad personalization. GA4 event data retention is 14 months. The Google Privacy Policy applies.

Cloudflare

This site uses Cloudflare's CDN, security protection (including bot detection), site performance statistics (Cloudflare Web Analytics), and Zaraz services, which may process IP addresses, HTTP request headers (such as browser type and referring URL), access timestamps, and the page URL to deliver pages, identify and prevent malicious traffic, and measure site performance. On every page load, whether or not you have agreed to analytics, the Zaraz loader sends Cloudflare the page URL and title, the referrer, screen and viewport size, color depth, character set, time-zone offset, and any browser storage whose name starts with _zaraz_; GA4 data is forwarded to Google by Zaraz only after you agree. According to Cloudflare, Web Analytics collects page-load performance data, a page identifier, the referrer, and the landing URL, uses no cookies or browser storage, and discards the IP address at the nearest data center without storing it. This site has set Web Analytics not to collect performance data from visitors connecting through Cloudflare data centers located in the EEA, the UK, or Switzerland (this depends on the connecting data center, not on your actual location); page delivery, security protection, and the Zaraz loader data described above are not affected by this setting. These performance statistics are not affected by the cookie choice below. The Cloudflare Privacy Policy applies.

Anonymous usage counts

This site counts anonymous usage events on /cards (switching tabs, clicking apply links, finishing the Finder, and changing the cards being compared), together with the page's region and language. It also records clicks on /go/ affiliate links on other pages, together with each link's short name (slug), the page path, the link's placement on the page, and the language, and counts presses of the 檢查 (Check) button on /editpen/, together with the language. All of these are used to improve content and features. Page paths are limited to pages listed in advance by this site and do not include URL query parameters. Text checking runs in your browser; the counts do not include the text you paste, its length, or the check results. These records are stored server-side on this site's Cloudflare account without IP addresses, cookies, or device identifiers; this counting does not save anything on your device and is not affected by the cookie choice below.

Newsletter subscription

If you voluntarily subscribe to Penchan Letter, this site processes the email address you submit, subscription time, subscription source, locale, subscription status, and technical information needed for Cloudflare Turnstile abuse-prevention verification. This site does not include your email address in the subscription result URL.

Cookies & Tracking Technologies

This site applies prior consent to all visitors: GA4 analytics (loaded both through the Google tag and through Cloudflare Zaraz) starts only after you select "Got it", and does not start if you make no choice or choose "Essential". The Cloudflare performance statistics, anonymous usage counts, and the page data sent by the Zaraz loader, described above, use no analytics cookies and are outside this choice.

Cookie Categories

• Necessary cookies and site data: Cookies required for Cloudflare security verification (such as cf_clearance and __cf_bm) and normal site operation, plus the cf_consent cookie and site data (cookie_consent in localStorage) that record your analytics consent status. They cannot be disabled and do not require consent.
• Analytics cookies: Used by Google Analytics 4 to understand site usage and improve content. Provider: Google LLC. Cookie lifetime: by Google's default, _ga and _ga_<container-id> last up to 2 years; when GA4 is loaded through Cloudflare Zaraz, Zaraz sets cookies with the same purpose, with lifetimes set by Cloudflare. GA4 event data retention: 14 months. Activated only after your consent and can be turned off at any time.
• Session storage: The browser's sessionStorage temporarily keeps the mobile menu state. It is cleared when you close the tab and is not sent to this site's servers.

Consent Management & Withdrawal

Analytics cookies are activated only after you select "Got it" in the cookie banner. Choosing "Got it" in the banner or on /cards pages means you agree to the analytics cookies described in this policy. On your first visit to /cards pages, a one-line notice linking to this policy appears next to the bottom tab bar, where you can choose "Essential" or "Got it"; you can change your choice at any time with "Cookies" in the footer. You can turn analytics cookies off at any time by choosing "Essential": select it in the cookie banner, or select "Cookies" in the site footer (including /cards pages) to choose again. Your choice is stored in this browser's site data (localStorage), and this site uses Google Consent Mode v2 analytics_storage controls to dynamically manage consent status. To reset it, you can also clear this site's data in your browser. Withdrawing consent does not affect processing carried out before the withdrawal.

You may also manage or reject cookies through browser settings, or use the Google Analytics Opt-out Add-on. The add-on may not block data sent server-side through Cloudflare Zaraz; choosing "Essential" stops both paths. Disabling necessary cookies may affect your browsing experience.

How We Use Data

Technical data, anonymous usage counts, and subscription data you voluntarily submit are used only to:

• Use aggregate statistics to understand reader preferences and improve content quality
• Use aggregate statistics to analyze site performance and user experience
• Maintain site security and prevent abuse
• Send the newsletter you voluntarily subscribed to, maintain subscription status, and prevent form abuse

This site does not sell personal data as a business, and does not proactively provide your data to third parties for their independent marketing purposes. However, third-party service providers may process necessary technical data according to their own privacy policies. This site does not use collected data for advertising delivery or remarketing.

You are free to choose whether to subscribe to the newsletter and whether to allow analytics cookies. If you do not subscribe, you simply will not receive the newsletter. If you do not allow analytics cookies, or turn them off, you can still read everything on this site and still subscribe to the newsletter.

Under Article 19(1)(5) of Taiwan's Personal Data Protection Act, this site collects GA4 analytics data and newsletter data with your consent. Page delivery, security protection (including Turnstile abuse checks), and Cloudflare performance statistics are processed under Article 19(1)(8) (no infringement of your rights and interests): the data is used only to deliver pages, block malicious traffic, and improve loading speed, and not to identify you, for advertising, or for profiling. If you are in the EEA or the UK, the legal basis for GA4 analytics and the newsletter is your consent (Article 6(1)(a) of the GDPR and the UK GDPR); for page delivery, security protection, and performance statistics it is this site's legitimate interest in providing the site securely and reliably and understanding how fast it loads (Article 6(1)(f)).

Third-Party Services

This site uses the following third-party services. Each service processes data under its own privacy policy:

• Cloudflare: CDN, security protection (including bot detection), DNS, performance statistics (Web Analytics), Zaraz (loads GA4), Workers Analytics Engine (anonymous usage counts)
• Cloudflare Pages Functions, D1, and Turnstile: Newsletter subscription processing, subscription-status storage, and automated-abuse prevention; Pages Functions also receive and validate anonymous usage events
• Google Analytics 4: Traffic analytics
• Google Workspace: Sending and receiving email to [email protected]
• ChatGPT (OpenAI) and Claude (Anthropic): Only when you press a rewrite button on /editpen/ does this site open the service you chose in a new tab and pass it your original text and the check results; for longer text, the prompt is first copied to your clipboard for you to paste yourself. From then on, that service's own privacy policy applies. Checking itself runs in your browser, and your text is not uploaded.
• Affiliate marketing partners, including but not limited to cryptocurrency exchanges: This site places links with referral parameters. After you click through to a third-party platform, that platform performs tracking under its own privacy policy. This site does not collect or store your behavior data on third-party platforms.

Cross-Border Transfer

Because this site uses Google (Analytics, Workspace) and Cloudflare services, some data may be transferred outside the Republic of China (Taiwan), including to the United States and to countries or regions where Cloudflare's global network operates, for processing and storage. Google LLC and Cloudflare, Inc. are both on the U.S. Department of Commerce's Data Privacy Framework participant list, covering the EU-U.S. framework, the UK Extension, and the Swiss-U.S. framework (checked September 25, 2026; Cloudflare's status is "Active - Re-certification under Review"). The European Commission has adopted an adequacy decision for transfers to U.S. companies participating in the framework, and the UK and Switzerland have made corresponding findings. Both companies' published data processing terms also include standard contractual clauses. For more information, contact [email protected].

Data Retention Period

• GA4 event data: 14 months
• Cloudflare logs: This site does not export or keep Cloudflare access logs. According to Cloudflare's documentation for the free plan this site uses, this site can view the last 7 days of request records and the last 24 hours of security events in its Cloudflare dashboard; these are the periods this site can view, not how long Cloudflare itself keeps the data. Cloudflare's own retention follows its privacy policy. For performance statistics, Cloudflare states that unsampled raw data is kept for 7 days and then stored as sampled aggregates, of which this site can view the last 6 months
• Anonymous usage counts: Stored in Cloudflare Workers Analytics Engine and retained for 3 months according to its service documentation
• Newsletter subscription data: Retained until you request deletion or this site ends the newsletter service. After you unsubscribe, the subscription record (email address, subscription time, subscription source, and locale) is kept with its status set to unsubscribed, so that no further emails are sent
• Email inquiries: Retained for up to 1 year after the response is completed, then deleted

Your Rights

Data Security & Incident Notification

This site takes reasonable technical and organizational measures to protect your access records, including HTTPS encrypted transmission and Cloudflare security protection.

If this site violates Taiwan's Personal Data Protection Act and your personal data is stolen, leaked, altered, or otherwise infringed as a result, this site will notify you in an appropriate manner after investigating (Article 12 as currently in force). The amendments to that Act passed in November 2025, including the duty to report to the competent authority, are not yet in force; once they are, this site will follow them.

External Links

Articles on this site contain links to exchanges, tools, and other external websites, including affiliate links. After you click away from penchan.co, this privacy policy no longer applies. Please refer to each website's privacy policy.

Minors

This site content involves financial market information and is mainly intended for adult readers. This site does not knowingly collect personal data from children under the age of 14. If this site learns that it has inadvertently collected personal data from a child under 14, it will delete the data as soon as possible.

Contact & Amendments

If you have any questions about this policy, please contact [email protected]. This policy may be revised due to legal changes or operational adjustments. Revised versions will be published on this site and the "Last updated" date will be updated.