COMIKEY MEDIA Inc. (referred to as “we”, “our” or “us”) respects your concerns about privacy. This Privacy Policy applies to the personal information we collect through COMIKEY application and/or website (collectively “Services”).

In this Privacy Policy, we describe the types of personal information we process through the Services, how we may use the information, with whom we may share it and the choices available to you regarding use of the information and exercising your rights. We also describe the measures we take to safeguard the information and tell you how to contact us about our privacy practices.

Information We Collect

The following personal information is collected in connection with the Services:

Information You Provide Directly

Some Services enable you to give us information directly. For example:

• When you create your own account and login to your account once created, we may need a username, email address and password.
• When you login to a third party account or to your profile with us, we may ask for information such as a username or profile picture.
• To provide responses when you contact our help services, we may collect any information you choose to provide, such as your requests or inquiries.
• When you communicate with our Customer Service staff or others, your communications will be transmitted through our systems through your email address.
• Your email - By registering with one of our Services, you consent to receiving periodic notifications including: relevant account notifications, order/download confirmations. In addition to these, you may receive notifications including: newsletters, forum topic digests and chat notifications. We will provide means to opt-out of any email notifications from us and will include links to opt-out in every email.

Information About Your Use of Services

In addition to the information you provide, we will collect information about your use of our Services through software on your devices and by other means. We will collect:

• Service usage information: your interactions with the Services (such as search terms, and the apps and features you use), dates and times of use of the Services, any Service usage information collected through cookies.;
• Information relating to the organization of contests and/or any promotional operations: date of participation, responses to the contests and nature of the prizes offered;
• Device and Log Information: Device and log information such as device model, OS version, IP address, setting of devices, country based on IP address, referrer, URL and network type; and
• Transaction Data: We only process technical information that does not allow us to identify you (e.g. transaction number) to validate the transactions.

Information collected through 3rd Party Analytics

Through certain Services, we may collect personal information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services. We may use third-party analytics services on the Services, such as Google Analytics and Sentry. The information we obtain may be disclosed to or collected directly by these providers and other relevant third parties who use the information, for example, to evaluate use of the Services or help administer the Services. 

• To learn more about Google Analytics: https://www.google.com/policies/privacy/partners/
• To learn more about Sentry: https://sentry.io/privacy/
• To learn more about BrainTree (Payment processor): https://www.braintreepayments.com/legal/braintree-privacy-policy

How We Use the Information We Collect

Provision of Services Based on Your Contractual Relationship With Us

• Provide a Service or feature you request, such as to respond to your request, questions and instructions made through Services;
• Conduct surveys and analyses necessary for improving the Service;
• Send you information and prizes for campaigns and events;
• Processing payment and billing when a user purchases a product or uses a Service which is not free;
• Provide you with tailored functions such as recommendation based on your most visited webpages and additional content tailored to your interests via the Interest tab;
• Identify and authenticate you so you may use certain Services; and
• Respond to your inquiries and send users important notifications when necessary.

Use of Information for Further Purpose

• Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities;
• Generate statistical data pertaining to usage of the services;
• Ensure and monitor the effectiveness and availability of the services to improve performance of the website and the application; and

• Comply with and enforce applicable law requirements, relevant industry standards and our policies, including this Privacy Policy.

Information Sharing

Comikey Media Inc. shares information whenever necessary to provide Services efficiently and in compliance with applicable law. We disclose personal information about you through the Services as described in the following:

• Service Providers. We may disclose your information to companies that provide Services on behalf of us, such as companies that help us develop and operate systems for the Service with customer contact centers, as well as customer care activities, advertising (including customized advertising on our websites, third-party websites, or online platforms), conducting customer satisfaction surveys, billing or that send emails on our behalf. These entities are limited by contractual provisions in their ability to use your information for purposes other than providing Services for us.
• Other Parties When Required by Law or as Necessary to Protect Our Services. There may be instances when we disclose your information to other parties:
• to comply with the law or respond to compulsory legal process (such as a search warrant or other court order);
• to verify or enforce compliance with the policies governing our Services; and
• to protect our rights, property, or safety, or, in compliance with data protection laws, any of our respective affiliates, business partners, or customers.
• Other Parties in Connection with Transactions. We may disclose your information to a third party as part of an actual or planned merger or transfer, acquisition or sale, or in the event of a bankruptcy.
• Other Parties with Your Consent or on Your Request. In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties when you separately consent to or request such sharing.
• Links to Other Websites, Devices, Apps and Features. The Service may provide the ability to connect to other websites, devices, apps and other features, which may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked website, device, app or other feature is not owned or controlled by us, we are not responsible for its content, use or privacy practices.

Retention of Personal Information

We take appropriate steps to ensure that we process and retain information about you based on the following logic:

• at least the duration for which the information is used to provide you with a service;
• as required under law, a contract, or with regard to our statutory obligations (e.g., tax laws); or
• only for as long as is necessary for the purpose for which it was collected, is processed, or longer if required under any contract, by applicable law, or, in anonymized form, for statistical purposes, subject to appropriate safeguards.

REQUEST TO DELETE PERSONAL INFORMATION

To submit an access or deletion request for personal information and/or account, please email us at support@comikey.com

To delete your Comikey account manually , go to the settings page of the Comikey app and click Delete Account

How We Protect Personal Information

We take protection of your information seriously and maintain safeguards designed to protect the information we collect in connection with the Services. However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system, or wireless connection is completely secure.

Updates to Our Privacy Policy

This Privacy Policy may be updated to reflect changes in our personal information practices with respect to the Service, or changes in the applicable law. We will post a notice on our Service to notify you in advance of material changes to our Privacy Policy and indicate at the top of the notice when it was most recently updated.

For California Consumers

This California section supplements the Comikey Privacy Policy and applies solely to California consumers.

Collection and Disclosure

We may have:

1. Collected the following categories of personal information about you:

• Identifiers such as a unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address, account name, and other similar identifiers;
• Financial information, such as signature, bank account number, credit card number, debit card number, and other relevant financial information;
• Commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies;
• Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements;
• Sensory information including electronic, visual, or similar information; and
• Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, behavior, attitudes, intelligence, abilities, and aptitudes.

2. Collected personal information about you from the following categories of sources:

• From you or your devices, for example, through your use of the Services;
• Our affiliated companies which provide services on our behalf, such as customer support and payment processing; and
• Social media networks.

3. Collected or sold personal information about you for the following business or commercial purposes (in addition to the purposes listed above in the Comikey Privacy Policy) :

• Performing Services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services;
• Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
• Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Debugging to identify and repair errors that impair existing intended functionality;
• Undertaking internal research for technological development and demonstration; and
• Undertaking activities to verify or maintain the quality or safety of a Service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the Service or device that is owned, manufactured, manufactured for, or controlled by us.

4. Shared your personal information with the following categories of third parties:

• Our affiliates, subsidiaries and business partners;
• Vendors who provide services on our behalf;
• Social networks;
• Professional services organizations, such as auditors and law firms; and
• Other third parties when you separately consent to or request such sharing.

5. We may also share your personal information with the following categories of third parties:

• A third party as part of an actual or planned merger or transfer, acquisition or sale, or in the event of a bankruptcy;
• Government entities, including law enforcement as required by law.

6. Sold the following categories of personal information about you: We may have sold advertising/marketing cookies to Google, Facebook, Twitter, Snapchat, Bing and TikTok in order to show you personalized advertisements based on your interactions with our Services when you visit such social media networks.

• Identifiers such as a unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; other forms of persistent or probabilistic identifiers), online identifier, and internet protocol address.
• Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements.
• Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

We do not knowingly sell the personal information of consumers at least 13 years of age and less than 16 years of age without prior authorization. We do not sell the personal information of consumers under the age of 13.

7. Disclosed for a business purpose the following categories of personal information about you:

• Data Analytics Providers: Identifiers such as a unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements.

California Consumer Privacy Rights

You may have the right to request, twice in a 12-month period, the following information about the personal information we have collected about you during the past 12 months:

• the categories and specific pieces of personal information we have collected about you;
• the categories of sources from which we collected the personal information;
• the business or commercial purpose for which we collected or sold the personal information;
• the categories of third parties with whom we shared the personal information; and
• the categories of personal information about you that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose.

You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties. In addition, you have the right to request that we delete the personal information we have collected from you. You also have the right to opt-out of the sale of your personal information. We will not deny, charge different prices for, or provide a different level or quality of goods or services because you choose to exercise these rights.

To submit an access or deletion request, email us at support@comikey.com . We will require that you provide us with your email address. When we receive your request, we will review the information that you provide and attempt to use it to verify your identity by comparing it against the information we have on file. You may also have an authorized agent, registered with the California Secretary of State, submit a request on your behalf. When we receive such a request, we will process the request, consistent with our standard process for verifying consumer requests. In addition, we may request information to demonstrate the agent’s authority to act on your behalf.

To opt-out of the sale of your personal information, email us at support@comikey.com. To help protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with your request. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.