Comici Inc. (“Comici,” “we,” “our,” or “us”) is committed to protecting your privacy. This privacy policy (“Privacy Policy”) explains how we collect, use, disclose, and safeguard your personal data as a data controller, when you use our services. Our services consist of providing software-as-a-service (SaaS) tools that enable the reading of online manga magazines (the “Services”). This Privacy Policy also outlines your rights regarding your personal data and explains how you can contact us with any questions about our privacy practices.

For the purposes of this Privacy Policy:

• “Personal Data” means any information relating to an identified or identifiable individual.
• “Processing of Personal Data” refers to any operation performed on personal data, whether or not by automated means, such as obtaining, recording, using, consulting, modifying, storing, restricting, disposing of, erasing, disclosing, aggregating, anonymizing, or de-identifying personal data.
• “Data Controller” means the entity that determines the purposes and means of processing personal data, in this case, Comici Inc. For the avoidance of doubt, this term shall be interpreted broadly to include any equivalent concept under applicable data protection laws, including, where relevant, the notion of a data fiduciary or any similar role as defined by local legislation.

The Data Controller responsible for the Processing of your Personal Data is:

Comici Inc.
Email: support@comici.jp
Address: Kanda Square 11th floor, 2-2-1 Kanda Nishikicho, Chiyoda-ku, Tokyo, Japan Representative Director: Daisaku Manda

We may collect the following categories of Personal Data directly from you:

We may also collect the following categories of Personal Data through tracking technologies such as cookies or SDK as described in the table below:

We may also process your Personal Data where necessary to comply with legal obligations or in our legitimate interests, including for the purposes of responding to judicial proceedings, law enforcement requests, or inquiries from governmental authorities.

We retain your Personal Data only for as long as necessary to fulfill the purposes described in this Privacy Policy and to comply with applicable legal and regulatory requirements.

To ensure transparency, we set specific retention periods depending on the purpose for which it was collected. These retention periods are outlined in the table below. Once a retention period expires, or if the data is no longer required for the stated purpose, we will securely delete, or anonymize your Personal Data, unless a longer retention period is required by law.

We may share your Personal Data with the following categories of recipients:

• Service Providers

We engage carefully selected service providers to support us in delivering our services (collectively, the “Service Providers”), as listed in the table below: 

These Service Providers may have access to your Personal Data, depending on their specific roles and purposes in facilitating and supporting our operations, and may only use it for such purposes and in accordance with our documented instructions and the agreements we have in place with them. All Service Providers are contractually bound by strict confidentiality obligations to ensure the protection of your Personal Data.

• Regulatory authorities, courts, and law enforcement

We may disclose or allow government and law enforcement officials access to certain Personal Data, in response to a subpoena, a search warrant or court order (or similar requirement) or in compliance with applicable laws and regulations, including for national security purposes. Such disclosure or access may occur with or without notice to you, if we believe, in good faith, that we are legally compelled to do so or that disclosure is appropriate in connection with efforts to investigate, prevent or take action regarding actual or suspected illegal activity, fraud or other wrongdoing.

• Other third parties in the event of corporate transactions

If our business undergoes a significant change, such as a merger, acquisition, reorganization, bankruptcy, dissolution, or the sale of all or part of our assets or shares, your Personal Data may be transferred as part of the transaction. In such cases, we will ensure that:- the recipient is bound by appropriate confidentiality and data protection obligations;- you are informed of any material changes in the way your Personal Data is processed as a result of the transaction.

As part of our business operations, your Personal Data may be maintained, processed, accessed, and stored by Comici and its Service Providers in Japan and the United States, as necessary for the proper management of our business or as required by law.

When we transfer your Personal Data outside the country of origin, we ensure that such transfers are carried out in compliance with this Privacy Policy and in accordance with applicable data protection laws, including through the implementation of appropriate safeguards such as adequacy decisions, standard contractual clauses, binding corporate rules or other transfer mechanisms.

We are committed to safeguarding your Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction. To achieve this, we implemented security measures, including:

• Strict access controls;
• Encryption of data in transit and at rest;
• Network security controls such as firewalls;
• Regular security training for all employees;
• Security policies and procedures, including incident response plan.

Depending on your place of residence, you may have certain rights in relation to your Personal Data. These may include the right to:

• Access your Personal Data and obtain a copy;
• Correct inaccurate or incomplete Personal Data;
• Request deletion of your Personal Data, where applicable;
• Restrict or object to the processing of your Personal Data;
• Receive your data in a portable format (data portability, where legally applicable);
• Withdraw your consent at any time, where processing is based on consent;
• Lodge a complaint with a competent supervisory authority if you believe your rights have been infringed.

How to exercise your rights

You may exercise your rights at any time by contacting us as described in the “Contact us” section below.

• We will verify your identity or the authority of your representative before processing your request. Depending on the content, we may require you to complete a designated application form.
• We will respond to your request without undue delay and, in principle, within one month of receipt, in accordance with applicable data protection laws.
• Our response will be provided through a method agreed with you, including electronic means.
• Requests are free of charge unless they are excessive or manifestly unfounded. In such cases, we may charge a reasonable fee or refuse to act.

To withdraw your consent, you can contact us as described in the “Contact us” section below or use the designated mechanism provided in your account through our website, or app. Please note that if you withdraw your consent, this may affect the Services we provide to you, for example, you may no longer receive personalized advertisements or tailored manga recommendations. Withdrawal of consent will not affect the lawfulness of any Processing carried out before your request. If no other legal basis exists for Processing your Personal Data, we will delete or anonymize your Personal Data in accordance with applicable laws.

Limitations and exceptions

In certain circumstances, we may not be able to fulfill your request, including when:

• Responding could harm the rights, freedoms, or safety of you or a third party;
• Fulfilling the request would infringe on our own rights or legitimate interests;
• Disclosure would violate laws or regulations; or
• Special procedures are prescribed by applicable law.

Any Personal Data collected in connection with a rights request will be used only to process that request and will be securely deleted once the process is complete.

Complaints

• Website: https://www.ppc.go.jp/
• Consultation Hotline: https://www.ppc.go.jp/personalinfo/pipldial
• Phone: +81-3-6457-9849
• Hours: 9:30 – 17:30 (excluding weekends, national holidays, and New Year holidays)

We may change this Privacy Policy from time to time. We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice by adding a notice on the Services homepages, login screens, or by sending you an email notification where you have subscribed to receive legal updates. We also keep prior versions of this Privacy Policy in an archive here. We encourage you to review our Privacy Policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this Privacy Policy, you will need to stop using the Services and deactivate your account(s) and/or submit a request to delete your Personal Data, as outlined in the “Your privacy rights” section.

Argentina

Legal basis. We process your Personal Data on one or more of the following legal bases:

• as necessary to enter into a contract with you or a legal entity you represent, to perform our contractual obligations, to provide you with our Services, to respond to requests from you, or to provide customer support;
• where we have a legitimate interest to maintain the integrity, availability, and security of the service, ensuring protection against fraud, misuse, and system failures and to ensure that you receive timely and relevant information that is essential for using the Services you signed up for;
• as necessary to comply with relevant law and legal obligations, including to respond to lawful requests and orders; or
• with your consent.

Profiling and automated decision making. We may use profiling to deliver personalized services and targeted advertising, but only with your prior consent. Profiling consists of analyzing certain aspects of your Personal Data such as your browsing behavior, preferences, or demographic information (e.g. age or gender, if you have provided consent) to better understand your interests and present relevant content. We do not use Personal Data for automated decision-making, including profiling, that produces legal effects or similarly significant impacts on individuals, unless appropriate safeguards are in place to protect your rights.

Brazil 

We are committed to addressing any concerns or complaints regarding the Processing of your Personal Data. If you have any complaints, you may contact us using the details provided in the “Contact us” section above. If you are dissatisfied with the resolution provided, you may file a complaint with Brazil’s National Data Protection Authority (ANPD) through its official channels.

European Union (“EU”)

Complaint. We are committed to addressing any concerns or complaints regarding the Processing of your Personal Data. If you have any complaints, you may contact us using the details provided in the “Contact us” section above. If you are dissatisfied with the resolution provided, you may lodge a complaint with your local supervisory authority. A full list of EU authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

Legal basis. We process your Personal Data on one or more of the following legal bases:

• as necessary to enter into a contract with you or a legal entity you represent, to perform our contractual obligations, to provide you with our Services, to respond to requests from you, or to provide customer support;
• where we have a legitimate interest to maintain the integrity, availability, and security of the service, ensuring protection against fraud, misuse, and system failures and to ensure that you receive timely and relevant information that is essential for using the Services you signed up for;
• as necessary to comply with relevant law and legal obligations, including to respond to lawful requests and orders; or
• with your consent.India

We are committed to addressing any concerns or complaints regarding the Processing of your Personal Data. If you have any grievances, you may contact us using the details provided in the “Contact us” section above. If you are dissatisfied with the resolution provided, you may escalate your complaint to the Data Protection Board of India.

Indonesia 

We are committed to addressing any concerns or complaints regarding the Processing of your Personal Data. If you have any grievances, you may contact us using the details provided in the “Contact us” section above. If you are dissatisfied with the resolution provided, you may escalate your complaint to the Personal Data Protection Agency (PDP Agency).

Philippines 

We are committed to addressing any concerns or complaints regarding the Processing of your Personal Data. If you have any complaints, you may contact us using the details provided in the “Contact us” section above. If you are dissatisfied with the resolution provided, you may escalate your complaint to the National Privacy Commission (NPC).

Thailand 

We process your Personal Data on one or more of the following legal bases:

• as necessary to enter into a contract with you or a legal entity you represent, to perform our contractual obligations, to provide you with our Services, to respond to requests from you, or to provide customer support;
• where we have a legitimate interest to maintain the integrity, availability, and security of the service, ensuring protection against fraud, misuse, and system failures and to ensure that users receive timely and relevant information that is essential for using the service they signed up for;
• as necessary to comply with relevant law and legal obligations, including to respond to lawful requests and orders; or
• with your consent.

Your rights. If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). These rights include: 

• To request information about our processing of your Personal Data;
• To request access to and/or a copy of certain Personal Data we hold about you (including in a portable and/or machine-readable format);
• To update or correct your Personal Data;
• To request that we delete certain Personal Data we hold about you, subject to certain exceptions;
• To limit use of sensitive Personal Data;
• To opt out of the “sale” of Personal Data, the “sharing” of Personal Data or “targeted advertising” (as these terms are defined under applicable laws) by clicking here;
• The right not to be discriminated against for exercising your rights; and
• The right to appeal our decision to deny your request, if applicable.

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:

European Union (EU)

Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website:https://app.prighter.com/portal/19188151158