In the course of and for the performance of our service of “pocket comics” (the “Service”), NHN comico Corp. (“NHN comico”, the “Company”, “we”, “our” or, “us”) processes various information about our customers who use the Service (“Customer”, “you”, or “your”). NHN comico recognizes the importance of the data protection for our Customers and establishes this Privacy Policy for the Service (the “Policy”) to provide you with our data protection policy and your rights concerning your Personal Data (as defined below). Please read this Policy carefully to understand our views and practices regarding your Personal Data and click a button to show your consent to this Policy to agree to our processing of your Personal Data.

1. Information We Collect

We collect information that identifies, relates to, describes, references, and is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Customer or Customer’s device (“Personal Data”). In particular, we will collect the following categories of Personal Data:

CategoryExamples
A. IdentifiersA unique personal identifier, online identifier, internet protocol address, and account name.
B. Commercial informationRecords of services purchased, or other purchasing histories (e.g. coin charge history).
C. Internet or other similar network activity informationBrowsing history, search history, and any other information on a consumer’s interaction with an application, or advertisement (e.g. Operating System, IDFA (iOS), ADID (Android), favorite, access log (all screens), click or tap log, language code, country code and time zone of the device, app version and browser information (user agent)).

We obtain your Personal Data directly or indirectly from you in our relationship with you, including, but not limited to, when you (i) make your personal account, (ii) apply to use the Service, (iii) access or use the Service, and (iv) communicate with us for inquiry about the Service.

2. Use of Personal Data

We may use the Categories A through C of Personal Data from the list above, for one or more of the following business purposes indicated below:

· to provide the Services and enable Customers’ efficient use of the Services;
· to process details regarding Customers’ use of the Services;
· to process and administer Customers’ personal account and registrations of the Service;
· to provide various services correspondence to the Customers (including to notify the Customers of changes to the Services);
· to process details of Personal Data that the Customers voluntarily provide on the Services;
· to perform, monitor and enforce contracts concluded between the Customers and the Company;
· to conduct research, analysis, develop our products;
· to provide notification of information related to the Service and our other products; and
· to serve advertisements to the Customers on our applications based on the use of the Services and/or on third-party sites and applications.

3. Legal Ground for Data Processing

We primarily process your Personal Data based on your consent to this Policy. If you wish to withdraw your consent, you may proceed at any time by informing us of the withdrawal of consent to us through our contact channel that is specified in this Policy. However, the withdrawal of consent will not affect the collection, use, or disclosure of Personal Data you have already given consent to the Company.
Other than where justified by your consent, we will usually process Personal Data where necessary (i) for the performance of contracts executed with you; (ii) for ensuring compliance with our legal obligations; or (iii) for our legitimate interests (or those of a third party), provided your interests and fundamental rights do not override those interests.

We will not intentionally collect Personal Data from a Customer under the age of 16 without obtaining consent from such Customer’s parent or legal guardian in advance. In the event that anyone under the age of 16 wishes to use the Services, we ask them to make sure that the consent is given or authorized by their guardian.
We will not collect additional categories of Personal Data or use the Personal Data we collect for materially different, unrelated, or incompatible purposes without providing you notice thereof.

4. Sharing, Disclosure or International Transfer of Personal Data

We may share or disclose your Personal Data to a third party for business purposes or commercial purposes, including but not limited to, with third party agents, suppliers, or contractors. When we disclose Personal Data to service providers for business purposes or commercial purposes, we enter a contract that describes such purposes and requires the service providers to both keep that Personal Data confidential and not use it for any purpose except for performing the contract.
In sharing or disclosing your Personal Data to a third party, we may transfer your Personal Data to countries outside your country of residence, such as Japan, the Republic of Korea and the United States. These countries may not have personal data protection laws as comprehensive as those that exist in your country of residence, and the same level of protection as that set forth in the personal data protection laws in your country may not necessarily be guaranteed. In such case, we shall implement necessary safety management measures pursuant to the requirement pursuant to any and all the applicable laws or legislations in respect with protection of your Personal Data (the “Applicable Law”).
We have not shared or disclosed any Personal Data in the preceding twelve (12) months.

5. Data Storage and Retention Period

Your Personal Data will be stored securely in our data server or in the third-party’s data server. We will strictly control access to this information and will review such access control from time to time. We will not keep your Personal Data for longer than required for the purpose of which it has been processed, in accordance with the Applicable Law or in any case to allow the Company to protect the legitimate rights and interests of its own or of third parties. To determine the appropriate retention period for the Personal Data, we shall consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of the Personal Data, the purposes for which we process the Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

6. Sales of Personal Data

We have not sold any Personal Data in the preceding twelve (12) months.

7. Your Rights and Choices under the Applicable Law

Pursuant to Applicable Law, you may have several rights on our processing of your Personal Data, which may include, to request access to, correction, or deletion of your Personal Data, restrict processing of your Personal Data, to ask for data portability, and to withdraw your consent to this Policy. You are also entitled to object to the processing of your Personal Data in certain instances.
When we receive a request based on your rights above, we will conduct all necessary investigations without delay and consider whether your request meets the criteria and condition to exercise such rights under the Applicable Law. For exercising your rights specified in this section, you can reach out to us by contacting to the person/department that is provided in the Section 8 (Contact Us).
You also have the right to lodge a complaint with the data protection supervisory authorities if you have any complaint regarding our processing of your Personal Data.
If you are a California resident, you may have certain additional rights. Please refer to the Privacy Policy for California Residents for more information.

8. Contact Us

If you have any questions or comments about this Policy, the ways in which we collect and use your information described above, or wish to exercise your rights provided in the Section 7 (Your Rights and Choices under the Applicable Law), please do not hesitate to contact us at:
inquiry@pocketcomics.com
To comply with General Data Protection Regulation, we have appointed a European representative. If you wish to contact them, their contact details are as follows:
· PLANIT // LEGAL
· mail@planit.legal
· Jungfernstieg 1, 20095 Hamburg, German

To comply with UK GDPR as defined in the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 United Kingdom, we have appointed a United Kingdom representative. If you wish to contact them, their contact details are as follows:
· TMI Associates London LLP
· london@tmi.gr.jp
· Citypoint One Ropemaker Street London EC2Y 9SS




Privacy Policy Last Updated and Effective: January 13, 2021

This Privacy Policy for California Residents (this “Policy”) conforms to the California Consumer Privacy Act of 2018 (the “CCPA”) and the California Online Privacy Protection Act of 2003, and supplements the information contained in our Privacy Policy. It applies to the handling of Personal Data of our Customers who are residents of California (“you”, or “your”).

1. Your Rights and Choices under CCPA

CCPA provides consumers who are residents of California with specific rights regarding Personal Data. If you are a California resident, this Section 1 describes your CCPA rights and explains how to exercise those rights.
(1)Access Right to Specific Information
You have the right to request that we disclose certain information to you about our collection, sharing, disclosure or use of your Personal Data over the past twelve (12) months from the time of your request. Once we receive and confirm your verifiable consumer request, we will disclose to you the following information:
· The categories of Personal Data we collected about you;
· The categories of sources for the Personal Data we collected about you;
· Our business or commercial purpose for collecting or selling that Personal Data;
· The categories of third parties with whom we share or sell that Personal Data;
· The categories of Personal Data sold by each third party who sold Personal Data;
· The categories of Personal Data disclosed for business purposes or commercial purposes; and
· The specific pieces of Personal Data we collected about you.
Please note that we have not sold any Personal Data in the preceding twelve (12) months.
(2)Deletion Request Rights
You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Data from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
· Complete the transaction for which we collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
· Debug products to identify and repair errors that impair existing intended functionality;
· Exercise free speech, ensure the rights of other consumers to exercise their free speech rights, or exercise other rights provided for by law;
· Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
· Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
· Comply with legal obligations; or
· Make other internal and lawful uses of that information that are compatible with the context in which you provided it. (3)Opt-Out Rights
We have not sold and will not sell any Personal Data collected from consumers.
(4)Non-Discrimination
We will not discriminate against California residents for exercising any of their rights under the CCPA. Moreover, unless permitted by the CCPA, we will not:
· Deny you the Service;
· Charge you different prices or rates for the Service, including through granting discounts or other benefits, or imposing penalties;
· Provide you a different level or quality of the Service; or
· Suggest that you may receive a different price or rate for the Service or a different level or quality of the Service.
(5)Exercising Access and Deletion Rights
To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by contacting us in the manner set forth in Section 4 (Contact Us).
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Data. You may also make a verifiable consumer request on behalf of your minor child.
The verifiable consumer request must:
· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative (e.g. a copy of your passport, residence certificate, etc.); and
· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond thereto.

2. Cookies and Similar Tracking Technologies

We or our third party partners may store some information on your device or device hard drive as a “cookie” or similar type of file (such as clear gifs, web beacons, pixels, tags, and similar technologies) to collect data related to usage of our application and for the purpose of facilitating and enhancing your communication and interaction with our application. We use this information to help us maintain and enhance the efficiency and usefulness of our application and may use it and other information about your Internet or other similar network activity for the purposes described in this Policy, such as to serve targeted advertising to you.
Cookies and similar items are not used by us to automatically retrieve Personal Data from your device without your knowledge. Please be advised that certain third parties that are beyond the scope of this Policy, such as advertisers, may collect information in connection with the application. We are not responsible for the acts or omissions of such third parties.
If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your device, please refer to and adjust your preferences. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our application or some of its functionality may be affected.
We do not respond to or honor “do not track” (a/k/a DNT) signals or similar mechanisms transmitted by web browsers.

3. Privacy Policy Updates

We reserve the right, at our discretion, to change, modify, add, or remove portions from this Policy at any time. However, if at any time in the future we plan to use personal information in a way that materially differs from this Policy, we will post such changes here or otherwise notify you in a manner that complies with law. We encourage you to periodically review our website for the latest information on our privacy practices.

4. Contact Us

If you have any questions or comments about this Policy, the ways in which we collect and use your information described above, or wish to exercise your rights provided in the Section 1 (Your Rights and Choices under CCPA), please do not hesitate to contact us at:
inquiry@pocketcomics.com




Privacy Policy for California Residents Last Updated and Effective: July 7, 2020

© NHN comico Corp.