Privacy Policy - Comic Years
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Privacy Policy

This privacy and cookie policy clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) we collect, use and process as a part of  our online offer and the websites, functions and contents connected with it as well as external online presences, such as our Social Media Profile. (hereinafter jointly referred to as the “online offer”).

Who we are

We are Comic Years (“we”, “our”, “us”) of 1501 Broadway, 12th Floor, Manhattan, New York, 10036-5601.  We operate to the highest standards when protecting your personal information and respecting your privacy. If you have any questions about your personal information, or how we use it, you can contact us using our contact form or email us at legal@comicyears.com.

We are the data “controller”, which means we are responsible for deciding how and why your personal information is used. We’re also responsible for making sure it is kept safe, secure and handled legally.

Applicable Data Protection Legislation

Data protection and data security are very important to us. For your further visits to our website, we would like to inform you about data collection, processing and use when visiting, registering and using our service. As well as objection, revocation and other rights to which you are entitled as a person affected by data collection and use. This we do in compliance with the applicable data protection legislation and have committed to a vast selection of Privacy Laws form across the globe based on our customer base. In particular we adhere to the;

  • New York State “Stop Hacks and Improve Electronic Data Security Act” (SHIELD Act)
  • Federal Trade Commission FIPs
  • California Consumer Privacy Act,
  • EU General Data Protection Regulation (GDPR)

 

Accuracy

 

It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.

What data do we process?

Inventory data (e.g., names, addresses).

  • Contact details (e.g., e-mail, telephone numbers).
  • Content data (e.g., text input, photographs, videos).
  • Contract data (e.g., object of contract, duration, customer category).
  • Usage data (e.g., websites visited, interest in content, access times).
  • Meta/communication data (e.g., device information, IP addresses).

 

Processing of special categories of data

No special categories data is processed.

Automated decision-making and profiling

We do not use automation for decision-making and profiling

 

Children Data

Our website is not intended for children and we do not knowingly collect data relating to children. If you become aware that your Child has provided us with Personal Data, without parental consent, please contact us and we take the necessary steps to remove that information from our server.

What are the categories of data subjects?

Customers, interested parties, visitors and users of the online offer, business partners. Visitors and users of the online offer. In the following, we refer to the data subjects collectively as “users”.

What are the purposes for processing?

  • Provision of the online offer, its contents and website functions.
  • Provision of contractual services, service and customer care.
  • Answering contact enquiries and communication with users.
  • Marketing, advertising and market research.
  • Security measures.

What are the relevant legal bases for processing your data?

The following informs you about the legal basis of us processing your data and unless the legal basis is not specifically mentioned, the following applies:

Consent – This is where we have asked you to provide explicit permission to process your data for a particular purpose.

Contract – This is where we process your information to fulfil a contractual arrangement we have made with you.

Answering your business enquiries – This is where we process your information to reply to your messages, e-mails, posts, calls, etc.

Legitimate Interests – This is where we rely on our interests as a reason for processing, generally this is to provide you with the best products and service in the most secure and appropriate way. Of course, before relying on any of those legitimate interests we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.

Legal Obligation – This is where we have a statutory or other legal obligation to process the information, such as for the investigation of crime.

Vital interests – This is where we process your information for communications about security, privacy and performance improvements of our services. Or for establishing, exercising or defending our legal rights.

 

Your Rights

You have a number of ‘Data Subject Rights’ below is some information on what they are and how you can exercise them.

  • information about the processing of your personal data.
  • obtain access to the personal data held about you.
  • ask for incorrect, inaccurate or incomplete personal data to be corrected.
  • request that personal data be erased when it’s no longer needed or if processing it is unlawful.
  • object to the processing of your personal data for marketing purposes or on grounds relating to your particular situation.
  • request the restriction of the processing of your personal data in specific cases.
  • receive your personal data in a machine-readable format and send it to another controller (‘data portability’).
  • request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers.
  • You also have the right in this case to express your point of view and to contest the decision
  • Where the processing of your personal information is based on consent, you have the right to withdraw that consent without detriment at any time through our contact form.

The above rights may be limited in some circumstances, for example, if fulfilling your request would reveal personal information about another person, if you ask us to delete information which we are required to have by law, or if we have compelling legitimate interests to keep it. We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your personal information. We encourage you to get in touch if you have any concerns with how we collect or use your personal information.

California Privacy Rights

Sources and Categories of collected personal information

(you can find all sources and categories of collected personal information above)

Business or commercial purpose for collecting information

(you can find all purposes of processing personal information above)

Categories of third parties with whom the business shares personal information

(you can find all categories of recipients of personal information listed above)

In addition to the rights as explained, under California’s “Shine the Light” law, California residents who provide personal information (as defined in the statute) to obtain products or services are entitled to request and obtain from us, once per calendar year, information about the personal information we shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared such personal information for the immediate prior calendar year (e.g., requests made in the current year will receive information about the prior year).

To obtain the information about data we hold about you or to effect the opt out, please write to us at the below address.

Do Not Track

Do Not Track is a privacy preference you can set in most browsers. We support Do Not Track because we believe that you should have genuine control over how your info gets used and our site responds to Do Not Track requests.

Do Not Sell My Personal Information

We do not sell information that directly identifies you, like your name or e-mail address. In fact, we do not even share that type of information except with service providers who can use the information solely to provide a service on our behalf, when a consumer directs us to share the information.

When do we disclose your Personal Data?

We may share your information with organizations that help us provide the services described in this policy and who may process such data on our behalf and in accordance with this policy, to support this website and our services. This will only be done on the basis of a legal authorization (e.g. if a transfer of the data to third parties, such as payment service providers.

 

Also, if you have consented to it, or where there we have a legal obligation to do so or on the basis of our legitimate interests (e.g. when using agents, hosting providers, tax, business and legal advisors, customer care, accounting, billing and similar services that allow us to perform our contractual obligations, administrative tasks and duties efficiently and effectively). If we commission third parties to process data on the basis of a so-called ” processing agreement”.

 

In relation to information obtained about you from your use of our website, we may share a cookie identifier and IP data with analytic and advertising network services providers to assist us in the improvement and optimisation of our website which is subject to our Cookies Policy.

 

We may also disclose information in other circumstances such as when you agree to it or if the law, a Court order, a legal obligation or regulatory authority ask us to. If the purpose is the prevention of fraud or crime or if it is necessary to protect and defend our right, property or personal safety of our staff, the website and its users.

International transfers

Our main operations are based in New York and your personal information is generally processed, stored and used within the USA. In some instances, your personal information may be processed outside the USA. If and when this is the case we take steps to ensure there is an appropriate level of security so your personal information is protected in the same way as if it was being used within the USA.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, the data processed by us will be deleted or restricted in their processing.  If the data is not deleted because they are required for other and legally permissible purposes, their processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

How do we protect your Personal Data?

We protect your data using state of the art technical, and physical safeguards and operate a firm system of policies, confidentiality agreements, digital safeguards and procedures to ensure the highest level of administrative protection.

In more detail to access our database the user must be authorized, is challenged through a two-way authentication system and use an encrypted VPN. Also, the removal of Personal Data from our location is forbidden and made by using a complex encryption system very difficult. We use cutting edge antivirus and anti-malware software and up-to-date firewall protection. Moreover, authorized personnel must have a legitimate need to know interest such as being your point of contact or service your user account.

The data we collect from you may be stored, with appropriate technical and organizational security measures applied to it, on our servers in New York. In all cases, we follow generally high data protection standards and advanced security measures to protect the personal data submitted to us, both during transmission and once we receive it.

To exercise any of your rights, or if you have any questions or complaints about our use of your Personal Data and this policy, please contact us using our contact form.

Economic Analyses and Market Research

In order to run our business economically, to identify market trends, customer and user wishes, we analyse the data available to us on business transactions, contracts, enquiries, etc. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata, whereby the persons concerned include customers, interested parties, business partners, visitors and users of the online offer. The analyses are carried out for the purposes of business management evaluations, marketing and market research.

 

In doing so, we may take into account the profiles of registered users with details, for example, of their purchasing transactions. The analyses serve us to increase user-friendliness, to optimize our offer and business efficiency and are not disclosed externally, unless they are anonymous analyses with summarized values.

 

If these analyses or profiles are personal, they will be deleted or made anonymous upon termination by the user, otherwise after two years from conclusion of the contract. In all other respects, the macroeconomic analyses and general trend determinations are prepared anonymously wherever possible.

Personal Identity Information (PII) Statement

Commercial Partners: Individual(s) or companies that have been approved by us as a recipient of organizational PII and from which Comic Years has received confirmation of their data protection practices conformance with the requirements of this policy. Commercial Partners include all external providers of services to Comic Years and include proposed Commercial Partners. No PII information can be transmitted to any vendor in any method unless the vendor has been pre-certified for the receipt of such information.

PII Training: All new hires entering Comic Years who may have access to PII are provided with introductory training regarding the provisions of this policy, a copy of this policy and implementing procedures for the department to which they are assigned. Employees in positions with regular ongoing access to PII or those transferred into such positions are provided with training reinforcing this policy and procedures for the maintenance of PII data and shall receive annual training regarding the security and protection of PII data and company proprietary data

PII Audit(s): Comic Years conducts audits of PII information maintained by Comic Years in conjunction with fiscal year closing activities to ensure that this policy remains strictly enforced and to ascertain the necessity for the continued retention of PII information. Where the need no longer exists, PII information will be destroyed in accordance with protocols for destruction of such records and logs maintained for the dates of destruction.

Data Breaches/Notification: Databases or data sets that include PII may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, Comic Years will notify all affected individuals whose PII data may have been compromised, and the notice will be accompanied by a description of action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible and in no event be later than the commencement of the payroll period after which the breach was discovered.

Confirmation of Confidentiality: All company employees must maintain the confidentiality of PII as well as company proprietary data to which they may have access and understand that that such PII is to be restricted to only those with a business need to know. Employees with ongoing access to such data will sign acknowledgement reminders annually attesting to their understanding of this company requirement.

Violations of PII Policies and Procedures: Comic Years views the protection of PII data to be of the utmost importance. Infractions of this policy or its procedures will result in disciplinary actions under Comic Years’ discipline policy and may include suspension or termination in the case of severe or repeat violations. PII violations and disciplinary actions are incorporated in Comic Years’ PII onboarding and refresher training to reinforce Comic Years’ continuing commitment to ensuring that this data is protected by the highest standards.

Collection of access data and log files

On the basis of our legitimate interests within the meaning of Article 6 paragraph 1 letter f. DSG, we collect data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the website previously visited), IP address and the requesting provider.

For security reasons (e.g. to clarify acts of abuse or fraud), log file information is stored for a maximum of seven days and then deleted. Data whose further storage is required for evidential purposes are excluded from deletion until the respective incident has been finally clarified.

Communication by mail, e-mail, fax or telephone

We use means of distance communication, such as post, telephone or e-mail, for business and marketing purposes. We process inventory data, address and contact data as well as contract data of customers, participants, interested parties and communication partners.

The processing is in connection with legal requirements for advertising communications. Contact shall only be established with the consent of the contact partners or within the scope of the statutory permissions and the processed data shall be deleted as soon as they are not required and otherwise with objection/ revocation or discontinuation of the basis for authorization or statutory archiving obligations.

Online presences in social media

We maintain online presences on the basis of our legitimate interests. We maintain online presences within social networks and platforms in order to communicate with customers, interested parties and users who are active there. Unless otherwise stated in this policy, we process the data of users if they communicate with us within the social networks and platforms, e.g. write articles on our online presences or send us messages.

What are Cookies?

Cookies are small pieces of data, stored in text files, that are stored on your computer or other device when websites are loaded in a browser. They are widely used to “remember” you and your preferences, either for a single visit (through a “session cookie”) or for multiple repeat visits (using a “persistent cookie”). They ensure a consistent and efficient experience for visitors, and perform essential functions such as allowing users to register and remain logged in. Cookies may be set by the site that you are visiting (known as “first party cookies”), or by third parties, such as those who serve content or provide advertising or analytics services on the website (“third party cookies”).

Both websites and HTML emails may also contain other tracking technologies such as “web beacons” or “pixels.” These are typically small transparent images that provide us with statistics, for similar purposes as cookies. They are often used in conjunction with cookies, though they are not stored on your computer in the same way. As a result, if you disable cookies, web beacons may still load, but their functionality will be restricted.

Advertising technologies

Our website uses the below technologies for advertising purposes. Those are modern, advanced analysis methods and tools to understand users’ habits on our website. This information helps us improve our products and services and provide relevant services and information. In principle, we use only anonymized data that does not allow us to identify the user.

Below we describe the analysis services and technology that we use for such purposes. Additionally, we show how you can prevent these services from analysis of your use of our website.

Google Analytics

We use Google Analytics to help us understand how you engage with our site so that we can improve it. Google Analytics reports website trends without identifying individual visitors. You may install a Google Analytics Opt-Out Browser Button here. The Google Analytics Privacy Policy can be read here.

Social Media Widgets

We display sharing buttons so you can use social networking to share items from our site. It also includes the recommend buttons and other interactive programs that run on our site that collect your IP address, which page you are visiting on our site, and sets a cookie to enable the widget to function properly. Your interactions with these Widgets are governed by the privacy policy of the company providing them.

How we use cookies

We use cookies for a number of different purposes. Some cookies are necessary for technical reasons; some enable a personalized experience for both visitors and registered users; and some allow the display of advertising from selected third-party networks. Some of these cookies may be set when a page is loaded, or when a visitor takes a particular action (clicking the “like” or “follow” button on a post, for example).

Types of Cookie

The table below explains the types of cookies we use on our websites and why we use them.

Category of cookies        Why we use these cookies
Strictly Necessary These cookies are essential for websites on our services to perform their basic functions.
Functionality These cookies are used to store preferences set by users.
Security We use these cookies to help identify and prevent potential security risks.
Analytics and Performance Performance cookies collect information on how users interact with our websites, including what pages are visited most, as well as other analytical data. We use these details to improve how our websites function and to understand how users interact with them.

 

Third Party Purpose Privacy Policy
Google Analytics Analytic, Measurement and Performance https://policies.google.com/privacy
https://tools.google.com/dlpage/gaoptout
https://policies.google.com/technologies/managing?hl=en
Google AdSense Targeting & Advertising
Google AdWords Targeting & Advertising
Google Tag Manager Essential, Functionality, Operation and Security
Alexa Analytic, Measurement and Performance https://www.alexa.com/help/privacy
Quantcast Analytic, Measurement and Performance https://www.quantcast.com/privacy/
ComScore Analytic, Measurement and Performance https://www.comscore.com/About/Privacy-Polic

 

Type of Information Purpose of Processing
Technical Information:

We may collect technical Non-Personal Information from you. This information includes the type of device, operating system and browsers you use, the time and date you accessed the Website, User’s actions (i.e., regarding its viewing and interaction with the Website and Website Content, including visited web pages and clickstream), your approximate geographical location, any redirecting URLs

We collect this information solely to operate, provide, maintain, protect, manage, customize and improve our Website and the Website Content.
Contact Details:

If you voluntarily contact us in any manner, or for any other request or notification, whether by submitting an online form that we make available through the Website (i.e., “Contact Us” page) or by sending an email to an email address that we display, or in any other manner, you may be required to provide us with certain information such as your name and email address which we will then process.

We will use your contact details only in order to respond to you, provide you with support, assist you or provide you with any other service that you request.
Online Identifiers:

We may collect certain online identifiers such as your IP addresses, for advertising, optimization, performance and analytic purposes, all as detailed in this Privacy Policy.

We use Online Identifiers for:

(i) our legitimate interests of operating, providing, maintaining, protecting, managing, and improving our Website and the Website Content; (ii) enhancing your experience and optimizing the Website Content based on your preferences; (iii) performing research, as well as for analytical and statistical purposes; (iv) our legitimate interests of auditing and tracking usage statistics and traffic flow, auditing our affiliates, calculating payments, detecting fraud, security or technical issues in connection with the Website; and (v) advertising purposes.

The Online Identifiers might be collected by us or by our third-party affiliates, analytic, optimization partners and advertisers, which their Cookies we use in our Website, as detailed in the “Cookies” section below.

 

HOW WE COLLECT INFORMATION

Depending on the nature of your interaction with the Website, we may collect the above detailed information from you, as follows:

  • In the event you voluntarily choose to provide us with information, when you contact us.
  • Automatically, including through the use of cookies (as detailed below), and other similar tracking technologies.

In the event required under applicable law and technically possible, we will ask for your consent to collect Personal Information, as well as offer you the choice to opt-out.

COOKIES

When you access or use the Website or the Website Content, we may use “Cookies” and similar tracking technologies. The use of Cookies is a standard practice. A “Cookie” is a small piece of information that a website assigns and stores on your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our services quicker and easier. Cookies are also used to help customize your experience. You can find more information about cookies at www.allaboutcookies.org.

Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You may remove cookies by following the instructions of your device preferences (as detailed below). However, if you choose to disable cookies, some features of the Website may not operate properly and your online experience may be limited.

Types of cookies used on our website:

There are several types of cookies that we use on our Website as follows:

  • Essential, Functionality, Operation and Security Cookies. These cookies are essential for enabling user movement around the Website, for the Website to function properly, and for security purposes (e.g., prevent fraudulent use). This category of cookies either cannot be disabled, or if disabled, certain features of the Website may not work.
  • Analytic, Measurement and Performance Cookies. These cookies are used to collect information about how users use our Website, in order to improve our services and the way we offer them, as well assess performance of the Website Content and the way it is displayed on our Website.
  • Targeting and Advertising Cookies. These cookies are set through our Website by our advertising partners. They may be used by these companies to build a profile of your interests and show you relevant ads on other sites. They work by uniquely identifying your browser and device and allowing the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of utmost interest to you. This Privacy Policy does not cover the use of cookies by any third party advertisers nor such third party advertisers’ related privacy practices, which have not been reviewed or examined by us. We encourage you to carefully read the privacy policies of all third parties whose services we use on the Website. The third party cookies that we currently use, the reason why we use them and their privacy policies are located in the table below.

 

Restricting the Use of cookies

 

If you do not want cookies to be stored on your computer, you can deactivate them using the corresponding option in your browser settings. The exclusion of cookies can lead to functional restrictions of this online offer. A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, particularly in the case of tracking, via the US site http://www.aboutads.info/choices/  or the EU site http://www.youronlinechoices.com/ .

 

Opt Out:

You may easily opt out of the data collection, sharing process and targeted advertising services related to our Website, as follows:

 

  • You may opt-out of each cookie category listed above (except strictly necessary cookies) by using the cookie management tool provided on the Website to change your settings preferences.
  • You may opt-out directly from third party retargeting cookies or other ad-technology trackers through self-regulator services like the Network Advertising Initiative’s (“NAI”) website – NAI consumer opt-out page or the Digital Advertising Alliance’s (“DAA”) website – DAA opt-out page.
  • As detailed above, we use third-party advertising companies to serve ads when you visit our Website. These companies may collect certain information about you in order to provide advertisements about goods and services of interest to you. These third party advertisers may provide ways for you to opt out from or limit their collection of information from and about you. Please refer to these third party’s privacy policies to learn more. Please see: http://www.networkadvertising.org/managing/opt_out.asp for more information.

 

Changes

 

This Privacy Policy and our commitment to protecting the privacy of your personal data can result in changes to this Privacy Policy. Please regularly review this Privacy Policy to keep up to date with any changes.

Queries and Complaints

Any comments or queries on this policy should be directed to us using the following contact details.

Comic Years

1501 Broadway, 12th Floor, Manhattan, New York, 10036-5601

legal@comicyears.com

www.comicyears.com

If you believe that we have not complied with this policy or acted otherwise than in accordance with data protection law, then you should notify us.