Add Comicslate Privacy Policy

Author: dotdoom

comicslate/privacy.md

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+## Privacy Policy of Comicslate
+
+*Last Updated: November 2, 2019*
+
+*This Application collects some Personal Data from its Users.*
+
+### Owner and Data Controller
+
+```
+Katarina Sheremet
+Albisstrasse 8
+8134 Adliswil
+Switzerland
+```
+
+Owner contact email: [katarina@sheremet.ch](mailto:katarina@sheremet.ch).
+
+### Types of Data collected
+
+Among the types of Personal Data that this Application collects, by itself or
+through third parties, there are: Cookies; Usage Data; first name; last name;
+email address; profile picture.
+
+Complete details on each type of Personal Data collected are provided in the
+dedicated sections of this privacy policy or by specific explanation texts
+displayed prior to the Data collection.  Personal Data may be freely provided
+by the User, or, in case of Usage Data, collected automatically when using this
+Application.
+
+Unless specified otherwise, all Data requested by this Application is mandatory
+and failure to provide this Data may make it impossible for this Application to
+provide its services. In cases where this Application specifically states that
+some Data is not mandatory, Users are free not to communicate this Data without
+consequences to the availability or the functioning of the Service.  Users who
+are uncertain about which Personal Data is mandatory are welcome to contact the
+Owner.
+
+Any use of Cookies – or of other tracking tools – by this Application or by the
+owners of third-party services used by this Application serves the purpose of
+providing the Service required by the User, in addition to any other purposes
+described in the present document and in the Cookie Policy, if available.
+
+Users are responsible for any third-party Personal Data obtained, published or
+shared through this Application and confirm that they have the third party's
+consent to provide the Data to the Owner.
+
+### Mode and place of processing the Data
+
+#### Methods of processing
+
+The Owner takes appropriate security measures to prevent unauthorized access,
+disclosure, modification, or unauthorized destruction of the Data.
+
+The Data processing is carried out using computers and/or IT enabled tools,
+following organizational procedures and modes strictly related to the purposes
+indicated. In addition to the Owner, in some cases, the Data may be accessible
+to certain types of persons in charge, involved with the operation of this
+Application (administration, sales, marketing, legal, system administration) or
+external parties (such as third-party technical service providers, mail
+carriers, hosting providers, IT companies, communications agencies) appointed,
+if necessary, as Data Processors by the Owner. The updated list of these
+parties may be requested from the Owner at any time.
+
+#### Legal basis of processing
+
+The Owner may process Personal Data relating to Users if one of the following
+applies:
+
+* Users have given their consent for one or more specific purposes. Note: Under
+  some legislations the Owner may be allowed to process Personal Data until the
+  User objects to such processing (“opt-out”), without having to rely on
+  consent or any other of the following legal bases. This, however, does not
+  apply, whenever the processing of Personal Data is subject to European data
+  protection law;
+* provision of Data is necessary for the performance of an agreement with the
+  User and/or for any pre-contractual obligations thereof;
+* processing is necessary for compliance with a legal obligation to which the
+  Owner is subject;
+* processing is related to a task that is carried out in the public interest or
+  in the exercise of official authority vested in the Owner;
+* processing is necessary for the purposes of the legitimate interests pursued
+  by the Owner or by a third party.
+
+In any case, the Owner will gladly help to clarify the specific legal basis
+that applies to the processing, and in particular whether the provision of
+Personal Data is a statutory or contractual requirement, or a requirement
+necessary to enter into a contract.
+
+#### Place
+
+The Data is processed at the Owner's operating offices and in any other places
+where the parties involved in the processing are located.
+
+Depending on the User's location, data transfers may involve transferring the
+User's Data to a country other than their own. To find out more about the place
+of processing of such transferred Data, Users can check the section containing
+details about the processing of Personal Data.
+
+Users are also entitled to learn about the legal basis of Data transfers to a
+country outside the European Union or to any international organization
+governed by public international law or set up by two or more countries, such
+as the UN, and about the security measures taken by the Owner to safeguard
+their Data.
+
+If any such transfer takes place, Users can find out more by checking the
+relevant sections of this document or inquire with the Owner using the
+information provided in the contact section.
+
+#### Retention time
+
+Personal Data shall be processed and stored for as long as required by the
+purpose they have been collected for.
+
+Therefore:
+
+* Personal Data collected for purposes related to the performance of a contract
+  between the Owner and the User shall be retained until such contract has been
+  fully performed.
+* Personal Data collected for the purposes of the Owner’s legitimate interests
+  shall be retained as long as needed to fulfill such purposes. Users may find
+  specific information regarding the legitimate interests pursued by the Owner
+  within the relevant sections of this document or by contacting the Owner.
+
+The Owner may be allowed to retain Personal Data for a longer period whenever
+the User has given consent to such processing, as long as such consent is not
+withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a
+longer period whenever required to do so for the performance of a legal
+obligation or upon order of an authority.
+
+Once the retention period expires, Personal Data shall be deleted. Therefore,
+the right to access, the right to erasure, the right to rectification and the
+right to data portability cannot be enforced after expiration of the retention
+period.
+
+### The purposes of processing
+
+The Data concerning the User is collected to allow the Owner to provide its
+Services, as well as for the following purposes: Analytics, Managing contacts
+and sending messages and Infrastructure monitoring.
+
+Users can find further detailed information about such purposes of processing
+and about the specific Personal Data used for each purpose in the respective
+sections of this document.
+
+### Detailed information on the processing of Personal Data
+
+Personal Data is collected for the following purposes and using the following
+services:
+
+#### Analytics
+
+The services contained in this section enable the Owner to monitor and analyze
+web traffic and can be used to keep track of User behavior.
+
+**Google Analytics for Firebase (Google LLC)**
+
+Google Analytics for Firebase or Firebase Analytics is an analytics service
+provided by Google LLC.
+
+**In order to understand Google's use of Data**, consult [Google's partner
+policy](https://www.google.com/policies/privacy/partners/).
+
+Firebase Analytics may share Data with other tools provided by Firebase, such
+as Crash Reporting, Remote Config or Notifications. The User may check this
+privacy policy to find a detailed explanation about the other tools used by the
+Owner. This Application uses identifiers for mobile devices and technologies
+similar to cookies to run the Firebase Analytics service.  Users may opt-out of
+certain Firebase features through applicable device settings, such as the
+device advertising settings for mobile phones or by following the instructions
+in other Firebase related sections of this privacy policy, if available.
+
+Personal Data collected: Cookies; Usage Data.
+
+Place of processing: United States – [Privacy
+Policy](https://policies.google.com/privacy). Privacy Shield participant.
+
+#### Managing contacts and sending messages
+
+This type of service makes it possible to manage a database of email contacts,
+phone contacts or any other contact information to communicate with the User.
+
+These services may also collect data concerning the date and time when the
+message was viewed by the User, as well as when the User interacted with it,
+such as by clicking on links included in the message.
+
+**Firebase Cloud Messaging (Google LLC)**
+
+Firebase Cloud Messaging is a message sending service provided by Google LLC.
+Firebase Cloud Messaging allows the Owner to send messages and notifications to
+Users across platforms such as Android, iOS, and the web. Messages can be sent
+to single devices, groups of devices, or specific topics or User segments.
+
+Personal Data collected: various types of Data as specified in the privacy
+policy of the service.
+
+Place of processing: United States – [Privacy
+Policy](https://policies.google.com/privacy). Privacy Shield participant.
+
+#### Infrastructure monitoring
+
+This type of service allows this Application to monitor the use and behavior of
+its components so its performance, operation, maintenance and troubleshooting
+can be improved.
+
+Which Personal Data are processed depends on the characteristics and mode of
+implementation of these services, whose function is to filter the activities of
+this Application.
+
+**Firebase Crashlytics (Google LLC)**
+
+Firebase Crashlytics is a monitoring service provided by Google LLC.
+
+Personal Data collected: various types of Data as specified in the privacy
+policy of the service.
+
+Place of processing: United States – [Privacy
+Policy](https://policies.google.com/privacy). Privacy Shield participant.
+
+### The rights of Users
+
+Users may exercise certain rights regarding their Data processed by the Owner.
+
+In particular, Users have the right to do the following:
+
+* **Withdraw their consent at any time**. Users have the right to withdraw
+  consent where they have previously given their consent to the processing of
+  their Personal Data.
+* **Object to processing of their Data**. Users have the right to object to the
+  processing of their Data if the processing is carried out on a legal basis
+  other than consent. Further details are provided in the dedicated section
+  below.
+* **Access their Data**. Users have the right to learn if Data is being
+  processed by the Owner, obtain disclosure regarding certain aspects of the
+  processing and obtain a copy of the Data undergoing processing.
+* **Verify and seek rectification**. Users have the right to verify the
+  accuracy of their Data and ask for it to be updated or corrected.
+* **Restrict the processing of their Data**. Users have the right, under
+  certain circumstances, to restrict the processing of their Data. In this
+  case, the Owner will not process their Data for any purpose other than
+  storing it.
+* **Have their Personal Data deleted or otherwise removed**. Users have the
+  right, under certain circumstances, to obtain the erasure of their Data from
+  the Owner.
+* **Receive their Data and have it transferred to another controller**. Users
+  have the right to receive their Data in a structured, commonly used and
+  machine readable format and, if technically feasible, to have it transmitted
+  to another controller without any hindrance. This provision is applicable
+  provided that the Data is processed by automated means and that the
+  processing is based on the User's consent, on a contract which the User is
+  part of or on pre-contractual obligations thereof.
+* **Lodge a complaint**. Users have the right to bring a claim before their
+  competent data protection authority.
+
+#### Details about the right to object to processing
+
+Where Personal Data is processed for a public interest, in the exercise of an
+official authority vested in the Owner or for the purposes of the legitimate
+interests pursued by the Owner, Users may object to such processing by
+providing a ground related to their particular situation to justify the
+objection.
+
+Users must know that, however, should their Personal Data be processed for
+direct marketing purposes, they can object to that processing at any time
+without providing any justification. To learn, whether the Owner is processing
+Personal Data for direct marketing purposes, Users may refer to the relevant
+sections of this document.
+
+#### How to exercise these rights
+
+Any requests to exercise User rights can be directed to the Owner through the
+contact details provided in this document. These requests can be exercised free
+of charge and will be addressed by the Owner as early as possible and always
+within one month.
+
+### Additional information about Data collection and processing
+
+#### Legal action
+
+The User's Personal Data may be used for legal purposes by the Owner in Court
+or in the stages leading to possible legal action arising from improper use of
+this Application or the related Services.
+
+The User declares to be aware that the Owner may be required to reveal personal
+data upon request of public authorities.
+
+#### Additional information about User's Personal Data
+
+In addition to the information contained in this privacy policy, this
+Application may provide the User with additional and contextual information
+concerning particular Services or the collection and processing of Personal
+Data upon request.
+
+#### System logs and maintenance
+
+For operation and maintenance purposes, this Application and any third-party
+services may collect files that record interaction with this Application
+(System logs) use other Personal Data (such as the IP Address) for this
+purpose.
+
+#### Information not contained in this policy
+
+More details concerning the collection or processing of Personal Data may be
+requested from the Owner at any time. Please see the contact information at the
+beginning of this document.
+
+#### How “Do Not Track” requests are handled
+
+This Application does not support “Do Not Track” requests.
+
+To determine whether any of the third-party services it uses honor the “Do Not
+Track” requests, please read their privacy policies.
+
+#### Changes to this privacy policy
+
+The Owner reserves the right to make changes to this privacy policy at any time
+by giving notice to its Users on this page and possibly within this Application
+and/or - as far as technically and legally feasible - sending a notice to Users
+via any contact information available to the Owner. It is strongly recommended
+to check this page often, referring to the date of the last modification listed
+at the bottom.
+
+Should the changes affect processing activities performed on the basis of the
+User’s consent, the Owner shall collect new consent from the User, where
+required.
+
+### Definitions and legal references
+
+#### Personal Data (or Data)
+
+Any information that directly, indirectly, or in connection with other
+information — including a personal identification number — allows for the
+identification or identifiability of a natural person.
+
+#### Usage Data
+
+Information collected automatically through this Application (or third-party
+services employed in this Application), which can include: the IP addresses or
+domain names of the computers utilized by the Users who use this Application,
+the URI addresses (Uniform Resource Identifier), the time of the request, the
+method utilized to submit the request to the server, the size of the file
+received in response, the numerical code indicating the status of the server's
+answer (successful outcome, error, etc.), the country of origin, the features
+of the browser and the operating system utilized by the User, the various time
+details per visit (e.g., the time spent on each page within the Application)
+and the details about the path followed within the Application with special
+reference to the sequence of pages visited, and other parameters about the
+device operating system and/or the User's IT environment.
+
+#### User
+
+The individual using this Application who, unless otherwise specified,
+coincides with the Data Subject.
+
+#### Data Subject
+
+The natural person to whom the Personal Data refers.
+
+#### Data Processor (or Data Supervisor)
+
+The natural or legal person, public authority, agency or other body which
+processes Personal Data on behalf of the Controller, as described in this
+privacy policy.
+
+#### Data Controller (or Owner)
+
+The natural or legal person, public authority, agency or other body which,
+alone or jointly with others, determines the purposes and means of the
+processing of Personal Data, including the security measures concerning the
+operation and use of this Application. The Data Controller, unless otherwise
+specified, is the Owner of this Application.
+
+#### This Application
+
+The means by which the Personal Data of the User is collected and processed.
+
+#### Service
+
+The service provided by this Application as described in the relative terms (if
+available) and on this site/application.
+
+#### European Union (or EU)
+
+Unless otherwise specified, all references made within this document to the
+European Union include all current member states to the European Union and the
+European Economic Area.
+
+#### Cookies
+
+Small sets of data stored in the User's device.
+
+#### Legal information
+
+This privacy statement has been prepared based on provisions of multiple
+legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data
+Protection Regulation).
+
+This privacy policy relates solely to this Application, if not stated otherwise
+within this document.