1. Data Controllers Comcraft has the sole controllership for processing personal information and share information as the sole controllers of your personal information to provide Services efficiently and in compliance with applicable law. In any event, you can contact us by email at info@thecomcraft.com: 2. Information We Collect The following personal information is collected in connection with the Services: Information you provide directly When you use our Services, you may provide us with your personal information after being informed of the privacy information at the time of collection. For example: - Contact information: When a user is considered a child in accordance with applicable law in user’s jurisdiction, we may need the user’s name and legal guardian’s e-mail address to obtain legal guardian’s consent depending on your jurisdiction. Moreover, when you participate in our events or promotions, we may ask for your name, phone number, address, email address and any other information required to deliver prizes and to respond to inquiries. - Account information: When you create your own account and login to your account, we may need your date of birth, nickname, email address and password. Additionally, when you login to a third party account or to your profile with us, we may ask for information such as nickname or profile picture. - Survey information: When you participate in our surveys or opinion polls, we may ask for your name, phone number, gender and any other information that can be reasonably required to conduct surveys or opinions and provide rewards. - Customer Care information: To provide responses when you contact our Customer Care, we may collect any information you choose to provide, such as your requests or inquiries. When you communicate with our Customer Care staff or others, your communications will be transmitted through our systems through your email address. - Identifiers such as a unique personal identifier (such as (i) device identifiers (e.g., cookies, beacons, pixel tags), (ii) mobile ad identifiers and similar technology, (iii) customer number, unique pseudonym, or user alias, (iv) telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address other similar identifiers. [For Creators] When you use Comcraft Website and/or Royalty Payment Agreement, we may need to collect the following additional information: - Creator Profile information: We may request information that you have voluntarily shared with the public through your Creator Profile page, including your profile picture, bio, social media links, website and more. - We may request that your PayPal ID or Patreon ID be linked to the Service. - We may request your uTip ID to provide reward or bonus. - Royalty Payment Information: If you choose to provide your PayPal account, we may ask for additional information such as your Name (Legal Name/Business Alias), Full name/Business Name, Country, Residency, Address, Postal code, E-mail, Signature and Tax ID (or Social Security Number when applicable) for tax processing purposes. Information collected through cookies and similar technologies - We and third parties may use cookies, web beacons, pixels, tags, and other tracking technologies (which we will refer to collectively as "cookies") to help us gather statistical information in order to improve your experience with the Services, save your preferences, and to provide you offers. These cookies may be used to track you across devices and websites over time. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org 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, dates and times of use of the Services and any Service usage information such as reading genre preferences, comments or likes, commercial information including purchase and transaction history, recent views; - Device and Log Information: Device and Log information such as device model, OS version, IP address, setting of devices, country information based on IP address, URL and network type; and - Transaction /Purchase details: we do not collect or process any payment details concerning you (e.g., credit card details). Such information is only collected and processed through Apple’s App Store, Google Play Store, and PayPal. The only information that Apple, Google and PayPal may share with us is transaction and purchase details (e.g., transaction number, purchase history). Such information is only processed to validate the transactions. - Inferences: We may draw inferences of your interests, preferences, and gender cohort based on information about your interactions with our Services or advertising partners. 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. 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. 3. How We Use the Information We Collect We may use the information collected above for the following purposes: [For Users and Creators] - Identify and authenticate you and administer your account - Provide a Service or feature you request, such as to respond to your request, questions and instructions made through the 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 that is not free; - Provide you with tailored functions such as recommendation based on your age and/or service usage information such as your most visited webpages, and additional content tailored to your interests; - Provide you with ads which may include personalized or targeted (or interest-based) ads; - Send you communications via email or in-product notifications (e.g., pop-up notification, push notification) in relation to our Services as controlled by your communication preferences; - Monitor and analyze trends, usage, and activities in connection with our products and services; - Create de-identified, anonymized or aggregated information; - Deliver and protect Digital Content; - Verify age and provide age-appropriate content and experiences; - Ensure the information security of our Services; - 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; - Comply with and enforce applicable law requirements, our statutory obligations (e.g., tax laws), relevant industry standards and our policies, including this Privacy Policy; - Validate transaction and prevent fraud and abuse; - Respond to your inquiries and send users important notifications when necessary; and - Carry out any other purpose described to you at the time the information was collected [For Creators using Comcraft Website and/or Royalty Payment Agreement] In addition to the above purposes, we may use the information collected on creators using Comcraft Website and/or Royalty Payment Agreement for the following additional purposes; - Verify your identity to comply with applicable federal laws; - Provide Royalty Payment Agreement to users; - Send emails relevant to your work or usage, as controlled by your email preference; - Reply to your questions; - Understand how you use the Service and create better Royalty Payment Agreements; - Generate statistical data pertaining to usage of the Services; - Conduct research and development to improve Royalty Payment Agreement and develop future products; - Comply with and enforce applicable law requirements, our statutory obligations (e.g., tax laws), relevant industry standards and our policies, including this Privacy Policy; and - Prevent fraud and abuse of Royalty Payment Agreement and prevent other criminal activity, claims and liabilities. 4. Information Sharing Comcraft shares information as the sole controllers of your personal information whenever necessary to provide Services efficiently and in compliance with applicable law. We disclose or share personal information about you through the Services as described in the following: - Publicly Available Information. Information that you have voluntarily registered to be shared with the public can be seen by anyone, including those who do not have an account. This may include your nickname, profile picture, short bio, social media links, website, other information on your public profile, and any information or content you share with a public audience. - 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. Acting as service providers in accordance with legal regulations, such suppliers may have access to your personal information in order to provide the services and/or comply with the obligations arising from the legal relationships maintained between the aforementioned third parties and us. In any case, we have signed the corresponding confidentiality and data protection agreements with those service providers, in full compliance with the provisions of current legislation on data protection. - Payment Partners. Payment and purchase information is collected and processed by payment partners for payment processing and anti-fraud purposes. - Advertising Partners. We may share your information to deliver more relevant advertising to you and help measure the effectiveness of ads. - Marketing Partners. We may share your information to enable you participate in our promotions, promote our Services in other platforms, and measure the effectiveness of our marketing activities. - Our Affiliated Companies. We may share your personal information with our subsidiaries for the purposes described in this Privacy Policy. - 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. 5. Retention of Personal Information We take appropriate steps to ensure that we process and retain information about you based on the following logic: - at the minimum 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. Thus, we will only keep your personal data for as long as we need it for the purposes for which we collect them and to comply with legal, financial, business or reporting requirements. When we no longer need the personal information, we will securely delete or destroy it. We will store the collected data even thereafter, until the expiration of any legal liability arising therefrom. 6. Your Rights Your personal information belongs to you. Depending on the jurisdiction in which you reside, you can ask us to provide details about what we’ve collected, and you can ask us to correct any inaccuracies. The details of your rights are as follows: Your right of access: you have the right to ask us whether or not we are using or storing your personal information. You can also ask us for copies of your personal information. Your right to rectification: you have the right to ask us to rectify information you think is inaccurate. You also have the right to complete information you consider is incomplete. Your right to erasure: you have the right to ask us to erase your personal information in the following circumstances: (i) we no longer need your personal information, (ii) you initially consented to the use of your personal information, but have now withdrawn your consent, (iii) you have objected to the use of your personal information and your interests outweigh those of our company, (iv) we have collected or used your personal information unlawfully, and/or (v) we have a legal obligation to erase your personal information. Your right to restrict processing: you have the right to ask us to restrict the processing of your personal information in the following circumstances: (i) you have challenged the accuracy of your personal information, (ii) you have objected to the use of your personal information, (iii) we processed your personal information unlawfully without you wishing to delete it, and/or (iv) we no longer need your personal information but you wish us to keep it in order to defend or exercise legal claims. Your right to object to processing: you have the right to object to the processing of your personal information if we are using your personal information for (i) a task carried out in the public interest, (ii) our legitimate interests, (iii) scientific or historical research or statistical purposes, or (iv) direct marketing. Your right to data portability: this right applies to personal information you have provided to us and where the processing is automated, based on your consent or made under a contract. You have the right to ask us, if technically feasible, to transfer your personal information to another organisation or directly provide it to you in a way accessible and machine readable. You also have the right to withdraw consent: at any time where the processing is based on your consent, without affecting the lawfulness of processing based on consent before such withdrawal. You have the right to lodge a complaint before a supervisory authority: you can lodge a complaint with the relevant supervisory authority if you consider that our processing of your personal information infringes applicable law. 7. Exercising Your Rights and Your Choices If you want to exercise the above rights or if you would like to submit your request, please contact us as specified in the Contact Us section (section 10 of this Privacy Policy). However, if permitted by law, we may charge you a small fee for providing you with this ability. Subject to applicable law, we may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, or for which access is not otherwise required by local law. You may access or correct your personal information registered with us at any time via the “Account” or “Creator Profile” page. You may ask us to delete your personal information by deleting your account at any time. If you have any series published on Comcraft, you must delete them first to delete your account. Once you delete your account, your account profile will be deleted permanently and become unrecoverable. Any tax information submitted to us will be maintained for a period of time, as required by financial laws and regulations. If you would like to change your preference regarding our communications (including marketing communications), you can change your communication preferences from “Account” page or “Settings” page. 8. 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. The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information as it is transmitted to us. To the extent permitted under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized access by third-parties or other causes beyond our control. You play an important role in keeping your information secure. You should not share your username or password for your account with anyone. If you have reason to believe that your account is no longer secure, please contact us immediately. 9. Children’s Personal Information The Services are designed for a general audience. If the consent of the parent (or legal guardian) is required to process the child's personal information pursuant to the applicable law, we will process such information upon obtaining consent of the parent (or legal guardian) in accordance with the legally required process. 10. Contact Us - If you have any questions, concerns or inquiries concerning the Policies for handling personal information, you may send them to our personal information management department at: Customer Care. - You can contact us by sending an email to our Data Protection Officer (DPO) at the following address: info@thecomcraft.com 11. Links to Other Websites You may identify hyperlinks to access the websites of other organisations on our websites or in the content we provide to you (e.g., promotional email or events). Please note that this privacy policy does not cover how other companies will process your personal information. We recommend you to read the privacy policies applicable to such other websites. 12. 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.