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POP COMICS LIMITED
PRIVACY POLICY

Last Updated: August 1, 2015

INTRODUCTION

Mascots

This Privacy Policy applies to the collection, use and disclosure of information that we may receive through your use of the “Platform,” which means the POP Comics platform for the sharing and viewing of online comics for mobile devices and personal computers. As used in this Privacy Policy, “POP Comics”, “we”, “us”, or “our” refer to POP Comics Limited, a Hong Kong limited liability company, and its subsidiaries; and “Users” and “you,” and “your” refers to visitors, users and others who access the Platform.

You understand and agree that the function of the Platform is to enable Users to post content, including online comics that Users have created (together, “User Content”), for other Users to view and comment to. User Content also includes any comments that you or other Users may post to online comics or other User Content. This means that if you post User Content or post comments in the Platform, other Users may search for, view, publicly comment to and share that User Content.

I.INFORMATION WE COLLECT
II. HOW WE USE YOUR INFORMATION
III. HOW WE COLLECT INFORMATION
IV. HOW WE SHARE YOUR INFORMATION
V. CHILDREN’S PRIVACY
VI. FRIEND-FINDING FUNCTION
VII. HOW WE PROTECT YOUR INFORMATION
VIII. HOW YOU MAY CHANGE OR REMOVE INFORMATION
IX. LINKS TO THIRD-PARTY WEBSITES AND SERVICES
X. UPDATES TO THIS PRIVACY POLICY
XI. TRANSFER OF INFORMATION
XII. YOUR CALIFORNIA PRIVACY RIGHTS; DO NOT TRACK DISCLOURE
XIII. CONTACTING POP COMICS

I. INFORMATION WE COLLECT

We may collect both personal information that identifies you and can be used to contact you and non-personal information, which is data in a form that does not allow direct association with you. Data that does not allow direct association with you may include technical information such as the IP address through which you are accessing the Platform and the mobile device IDs (including Unique Device Identifier (UDID), Media Access Control (MAC), Advertising ID and Vendor ID) and International Mobile Station Equipment Identity (IMEI) (together, “Device Identifiers”) for the mobile device you may be using. We may also collect mobile device location information, subject to your consent provided through your device.

A. Personal Information

Personal information may include, but is not limited to, your name, e-mail address, date and year of birth, and any personal photo or image representation that is uploaded in your personal profile. We will collect, use and disclose personal information only as described in this Privacy Policy.

Please note that some non-personal information would be considered a part of your personal information if it were combined with other information in a way that enables you to be identified, but the same information is considered non-personal information when taken alone or combined only with other non-personal information.

Please note that User Content is not considered personal information for purposes of this Privacy Policy, and will not be treated as personal information by POP Comics, even if you have included information in User Content that would otherwise be considered personal information. As a result, we strongly advise you not to include personal information in User Content.

B. Non-Personal Information

Non-personal information, alone, cannot be used to identify or contact you. POP Comics collects non-personal information about your use of the Platform and includes aggregated information regarding usage of the Platform. The non-personal information collected may include information related to your mobile device or computer system, including Device Identifiers and country of registration. It may also include browser type, language, Internet Service Provider (ISP), referring and exit pages, time spent, information searched for, time and date stamp, clickstream data, feature usage, User Content posted and User Content viewed, comments posted and other statistics. POP Comics also collects login information, user ID and other information from any social networking site (“SNS”) that you may use to access the Platform, or that you may interact with through the Platform, as described in more detail under the subsection below “Interaction with SNS’s”. Non-personal location also includes information on the location of your device.

II. HOW WE USE YOUR INFORMATION

Generally, we use your information to provide you with an efficient and customized experience. For example, we may use information in the following ways:

  • To send important notices, such as communications about User Content you have posted or commented to and changes to our Terms of Service and this Privacy Policy;
  • To inform you about new POP Comics features and promote products and services of POP Comics and its affiliated companies;
  • To send “push” notifications to your mobile device regarding newly-posted User Content or other developments in the Platform that we think may be of interest to you;
  • To identify and suggest connections with other Users or with users of an SNS that you use in connection with the Platform;
  • To enable communications between you and other Users or users of an SNS that you use in connection with the Platform;
  • To send payments to you with respect to advertising appearing with your User Content, if we have such an arrangement in place from time to time;
  • To allow us to enable you to reset your password if you have forgotten it;
  • To provide technical support and respond to inquiries from you;
  • To prevent fraud and potentially illegal activities and enforce our Terms of Service;
  • To help us to develop, deliver and improve the Platform;
  • For market research purposes that support our efforts to deliver a more valuable service to our community of POP Comics users;
  • To deliver and target advertising from our corporate affiliates and third parties;
  • To gather demographic information about Users in order to more effectively manage the Platform and provide targeted advertising; and
  • To track clicks or other ad fulfillment metrics.

If we send e-mail or SMS messages to you for the purpose of promoting POP Comics products or services, or those of corporate affiliate or third-party partner, we will provide you with choices about receiving further such promotional messages. Preferences for “push” notifications may in most cases be adjusted through the Platform or your mobile device.

III. HOW WE COLLECT INFORMATION

A. User Registration

We collect information that you provide us when registering to use the Platform and/or uploading User Content. This may include your name, location, e-mail address and other items.

B. Interaction with SNS’s

By logging in to the Platform using your SNS login information, you allow POP Comics to access certain information from your profile for that SNS. The information you allow POP Comics to access may be affected by the privacy settings you and your friends have established with that SNS. You can control and find out more about these settings directly from the SNS. For example, POP Comics may access and store some or all of the following information, as allowed by you, the SNS and your preferences:

  • Your first and last name;
  • Your SNS user ID;
  • Your user ID number, which is linked to publicly available information such as name and profile photo
  • The user ID numbers and other public data for your friends;
  • The URL of your SNS profile;
  • The login e-mail address you provided to that SNS when you registered; and
  • Your gender.

POP Comics may enable you to log in to the Platform through an interface provided by that SNS, and POP Comics may also enable you to access the SNS through the Platform. If you log in to the Platform using an SNS, or access an SNS through the Platform, we may receive the personal and non-personal information that you have provided (or provide in the future) to that SNS.

By connecting the Platform to an SNS, you consent to POP Comics’ access, use and storage in accordance with this Privacy Policy of any and all of the information that the SNS provides to POP Comics.

You may be able to specify what information is provided by the SNS to POP Comics using the privacy settings in your SNS profile information.

C. Cookies and Other Technologies

A cookie is a small string of text that we, or service providers acting on our behalf, such as Google Analytics or other analytics services, send to your computer’s or mobile device’s browser. Other types of cookies exist, but the cookies set by POP Comics are only used to obtain browser or device-specific information.

Some cookies are necessary for the Platform to function properly or to prevent you from having to reenter your information each time you access the Platform. Other cookies can show, for instance, which parts of the Platform are the most popular, how much time users are spending there, and how they are interacting with the content. Cookies may be linked to your POP Comics user ID. Cookies set by POP Comics do not collect information from your computer or mobile device that is not related to the Service.

You may have the option to disable cookies by changing the options in your browser to stop accepting cookies or to prompt you before accepting a cookie from the pages you visit. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on's settings or visiting the website of its manufacturer. If you do not accept cookies, however, you may not be able to use all portions of the Platform.

We may also use “pixel tags,” “web beacons,” “clear GIFs” or similar means (individually or collectively “pixel tags”) in connection with the Platform and to collect usage, demographic and geographical location data. A pixel tag is an electronic image, often a single pixel that is ordinarily not visible to users and may be associated with cookies on a user’s mobile device or hard drive. pixel tags allow us to count users who have visited certain pages of the Platform and to help determine the effectiveness of promotional or advertising campaigns.

Please note that third parties delivering advertisements through the Platform may also use cookies or other technologies. Their placement and use of cookies and other technologies will be subject to their own privacy policies and terms and conditions.

BY CLICKING ON THE “SUBMIT” BUTTON, WHERE APPLICABLE, OR OTHERWISE BY ACCESSING OR USING OUR SERVICES YOU ARE CONSENTING TO THE USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES ON YOUR COMPUTER OR DEVICE.

D. Location Information

Subject to your consent, provided through our mobile device, the Platform may collect information on the location of your device. You may revoke your consent at any time through the settings on your mobile device; however, in that case certain features in the Platform may no longer function properly.

E. Other

POP Comics may provide you the opportunity to participate in sweepstakes or contests. If you choose to participate in a sweepstakes or contest, we may request that you provide us with personal information such as your name, e-mail address and physical mailing address.

If POP Comics has in effect a program of paying Users with respect to advertising appearing with their User Content, we may request your e-mail address or other information required in order to send payment to you, and such e-mail address or other information may be used for purposes other than making such payments, to the extent set forth in this Privacy Policy.

If you request support relating to the Platform, we may request personal information such as your name and e-mail address and your user name for any SNS’s, if that appears necessary to resolving the problem.

If a User allows us to collect information from their contacts or SNS friends, and you are included in those contacts or friends, we may combine that information with other information that we may have concerning you. We may also obtain information from other sources and combine that information with any of your information collected through the Platform.

We may also request or receive personal information in other interactions you may have with POP Comics.

IV. HOW WE SHARE YOUR INFORMATION

A. Within the Platform

Other Users may have the ability through the Platform to view profile information concerning you.

When you post User Content within the Platform, certain profile information concerning you may appear to identify the User Content as having come from you.

  • If you allow us to search your contacts or SNS friends and consent to our contacting them, we may refer to your name, user ID and e-mail address in our communication to those individuals inviting them to join POP Comics.

B. With Third-Party Advertisers

POP Comics will not provide your personal information with third-party advertisers, ad networks or ad platforms ("Advertisers") for their direct marketing purposes unless you provide your consent.

We may share certain non-personal information with Advertisers to develop and deliver targeted advertising in the Platform and on the websites of third parties. In addition, Advertisers may collect non-personal information within the Platform, including your IP Address and Device Identifiers, device type, device brand, device model, OS type/version, network type, device language and device locale. Advertisers may also collect non-personal information related to the performance of the advertisements, such as how many times an advertisement is shown, how long an advertisement is viewed, and any click-throughs of an advertisement.

Advertisers may obtain non-personal information through the collection of Device Identifiers and use of tracking technologies like cookies and pixel tags, and may use that non-personal information to track Users over time and across different websites and services and deliver targeted advertising. For more information about interest-based ads, including how to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices.

C. With Service Providers

We may allow data analytics services and other third-party service providers to collect information about how you use the Platform, including by using cookies and pixel tags and obtaining Device Information.

These service providers will have access to your information only to perform the services they have been engaged to perform for us, and they have agreed not to use it for any other purpose. They have also agreed not to disclose such information to third parties except under limited circumstances.

D. Under Special Circumstances

We may disclose information about you to law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of POP Comics or a third party, to protect the safety of any person or to prevent or stop activity we may consider to be illegal or unethical.

In connection with a merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy, we may sell, transfer or otherwise share some or all of POP Comics assets, including your personal information.

We may share your information with your consent or at your direction.

E. Aggregated Information

We may share aggregated or de-identified information, which may not reasonably be used to identify you, with any person or entity and in any manner we choose.

V. CHILDREN’S PRIVACY

POP Comics is not intended for children under the age of 13. We do not knowingly collect any personal information from children under the age of 13.

VI. FRIEND-FINDING FUNCTION

The Platform may include a function that may help you to identify friends with whom you may wish to interact in the Platform. At your option, the function may access your contacts on SNS’s, or may scan your computer or mobile device.

Your use of the friend-finding function in connection with an SNS is subject to your user agreement with the SNS, and any policies of that SNS.

VII. HOW WE PROTECT YOUR INFORMATION

POP Comics is committed to protecting the security of your information. We have implemented security measures to protect against identity theft and unauthorized access.

We do not and will not, at any time, request your credit card information, your login information or other identification in a non-secure or unsolicited communication (such as e-mail).

Should any breach of security occur, we will make any legally required disclosure to you by e-mail or posting on the Platform as soon as reasonably possible, subject to (i) the requests of law enforcement and (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

VIII. HOW YOU MAY CHANGE OR REMOVE INFORMATION

You may email us at legal@popcomics.com to request that we delete your personal information from our database. In that case, please place “delete my account” in the subject line and include your first and last name and e-mail address in the body of the message. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for business administrative purposes.

Please note that communications you may send through the Platform, as well as any comments you may post, will be stored by POP Comics, and may not be subject to modification or deletion.

The Platform may contain links to other websites and online services, including third-party advertisements. If you choose to click through to one of these other websites or online services, please note that any information you may provide will be subject to the privacy policy and other terms and conditions of that websites or service, and not to this Privacy Policy. We do not control third-party websites or services, and the fact that a link to such a website or service appears in the Platform does not mean that we endorse them or have approved their policies or practices relating to user information.

Before providing any information to any third-party website or service, we encourage you to review the privacy policy and other terms and conditions of that website or service. You agree that POP Comics will have no liability for any matters relating to a third-party website or service that you provide information to, including their collection and handling of that information.

X. UPDATES TO THIS PRIVACY POLICY

We reserve the right to update this Privacy Policy at any time. If we modify this Privacy Policy in a material way, a notice will be posted on the Sites along with the updated Privacy Policy. We will also update the “Last Updated Date” in the Privacy Policy. “Privacy Policy” as used herein includes any updates and modifications we may make from time to time.

By continuing to access or use the Platform after we have posted an updated Privacy Policy or have provided you with notice of a modification, you agree to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, you must immediately stop using any Platform.

XI. TRANSFER OF INFORMATION

POP Comics is based in the Hong Kong Special Administrative Region. Information that you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. If you are located in the European Union, you freely consent to the transfer of personal information outside of the European Union. Your consent to this Privacy Policy followed by your submission of personal information represents your agreement to these transfers.

XII. YOUR CALIFORNIA PRIVACY RIGHTS; DO NOT TRACK DISCLOSURE

If you are a resident of the State of California, USA and POP Comics user, you are entitled to request certain information regarding our disclosure of certain “personal information” (as defined in California Civil Code Section 1798.83) to third parties for their direct marketing purposes. If you are a California resident and have provided POP Comics with personal information within the last year, you may make such a request by emailing us at legal@popcomics.com and typing the following in the subject line of the e-mail: “California Privacy Rights”.

Within 30 days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for such third parties’ direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. A request may be made no more than once per calendar year and we are not required to respond to requests made by means other than through the e-mail address above.

POP Comics does not currently respond to “Do Not Track” signals in Users’ browsers or similar mechanisms.

XIII. CONTACTING POP COMICS

If you have any questions, inquires, requests or complaints concerning this Privacy Policy or our information practices, please contact us at legal@popcomics.com or by regular mail at the following address: Privacy Officer, POP Comics, Inc., Unit 02-07, Berkshire House, 25 Westlands Road, Quarry Bay, Hong Kong Special Administrative Region.