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Privacy Policy

Last revised: March 03, 2026

Purpose

The purpose of this Privacy Policy is to inform you how Platforma Digital Inc. (hereinafter - “Comicrush”, “we”, “us”, or “our”) processes personal data when you visit, access, or use https://comic-rush.com/en (hereinafter - the “Website” or the “Service”), including when you create an account, purchase subscriptions, digital content, virtual items (including Сoins), or otherwise engage in paid features of the Service, or otherwise interact with the Service.

For the purposes of applicable data protection laws, Comicrush acts as the data controller in respect of personal data processed through the Website, unless expressly stated otherwise in this Privacy Policy.

This Privacy Policy explains:

  • what personal data we collect;
  • how and why we use such data;
  • with whom such data may be shared;
  • how personal data may be processed in connection with payments, subscriptions, and third-party service providers supporting the Service;
  • the choices and rights available to you regarding your personal data; and
  • the measures we take to protect your privacy.

We process personal data in accordance with applicable data protection and privacy laws, where and to the extent they apply, including but not limited to the EU General Data Protection Regulation (GDPR), the UK GDPR, the California Consumer Privacy Act (CCPA/CPRA), COPPA, any other emerging U.S. online child-safety requirements, where and when applicable, and other applicable national data protection laws depending on your location. References to “personal data” in this Privacy Policy have the meaning given under the applicable data protection laws.

This Privacy Policy is intended to meet transparency obligations under applicable data protection laws and to serve as a general description of our privacy practices. The specific legal rights and obligations that apply to you may vary depending on your jurisdiction.

By accessing or using the Website, you acknowledge that you have read and understood this Privacy Policy. This acknowledgment does not replace or override any separate consent required under applicable law. Where required by applicable law, certain data processing activities (such as cookies, marketing communications, or personalized content) are subject to your separate and explicit consent and are not based solely on your continued use of the Website.

We may update this Privacy Policy from time to time. Where required by law, we will notify you of material changes via reasonable means, such as email or in-Service notices. Otherwise, the updated version will be made available on this page, and the “Last updated” date will be revised accordingly.

Controller details (EU/EEA and other regions where applicable)

Platforma Digital Inc. (“Comicrush”) is the controller for personal data processed through the Website.

Contact: Platforma Digital Inc..

Email (privacy): [email protected].

Types of personal data we collect

We collect personal data to provide, operate, secure, and improve the Service, to process subscriptions and payments, and to comply with applicable legal obligations. Personal data is collected and processed only to the extent necessary for the purposes described in this Privacy Policy and in accordance with applicable data protection laws, including the GDPR and relevant U.S. privacy regulations. The categories of personal data we collect depend on how you interact with the Service and may include the following:

A. Personal data you provide directly to us

When you create an account, subscribe to the Service, contact us, or otherwise interact with the Website, you may provide us with the following personal data:

  • email address;
  • account credentials (such as username and password);
  • confirmation that you are 18 years of age or older (or the age of legal majority in your jurisdiction, if higher), as required to create an account and access the Service.
  • data provided when contacting customer support, submitting inquiries, or sending feedback;
  • data provided in connection with surveys, promotions, or communications with us.

You are responsible for ensuring that the personal data you provide is accurate, complete, and up to date.

B. Payment and transaction data

When you purchase a Subscription or Coins, payments are processed by third-party payment service providers.

We do not collect or store full payment card numbers or complete cardholder data.

We may receive limited payment-related data, such as:

  • payment status;
  • transaction identifiers;
  • the first six and last four digits of a payment card, where permitted under the PCI DSS standards;
  • billing country and currency.

This data is used solely for payment processing, fraud prevention, chargeback management, refunds, accounting, and legal compliance.

All payment data is primarily processed and stored by our payment service providers in accordance with their own privacy and security policies.

Comicrush does not act as a data controller in respect of full payment card data processed by third-party payment service providers and does not have access to such data.

C. Automatically collected technical and usage data

When you access or use the Service, we may automatically collect certain technical and usage data, including:

  • IP address;
  • browser type and version;
  • operating system;
  • device type, model, and identifiers;
  • language preferences;
  • pages viewed, features used, interaction patterns, time, and duration of visits;
  • referring URLs and navigation paths.

This personal data helps us operate the Service, ensure security, detect abuse, and improve performance and user experience.

Such processing is necessary for the legitimate operation, security, and maintenance of the Service.

D. Cookies and other similar tracking technologies

We use cookies and similar tracking technologies (such as pixels, local storage, and SDKs) to:

  • enable core functionality of the Website;
  • remember user preferences;
  • support authentication and security;
  • analyze usage and performance of the Service;
  • support analytics and measurement tools.

Where required by applicable law (including EU law), cookies that are not strictly necessary are used only with your consent. Where consent is required, you may withdraw or modify your consent at any time through the applicable cookie settings or consent management tools, without affecting the lawfulness of processing prior to withdrawal. You can manage cookie preferences through your browser settings or any cookie consent tools provided on the Website.

E. Analytics and service improvement data

We may use analytics tools and services (including, in the future, third-party analytics providers such as Google Analytics or similar technologies) to understand how users interact with the Service.

These tools may collect data such as:

  • usage patterns;
  • aggregated statistics;
  • interaction metrics;
  • device and browser data.

Analytics data is used in aggregated or pseudonymized form where possible and is processed in accordance with applicable data protection laws.

Where third-party analytics providers are used, such providers act as data processors or independent controllers in accordance with their respective privacy policies and applicable law.

F. Location-related data

We may infer your approximate location based on your IP address for purposes such as:

  • security and fraud prevention;
  • compliance with legal or regulatory requirements;
  • regional availability of content;
  • analytics and service optimization.

We do not collect precise real-time GPS location data unless explicitly enabled through device settings and required for a specific feature.

Approximate location data derived from IP addresses does not allow us to determine your precise physical location.

G. Special categories of personal data

We do not intentionally collect or process special categories of personal data (such as data revealing racial or ethnic origin, political opinions, religious beliefs, health data, or sexual orientation).

Please do not provide such data to us through the Service.

Children and age-restricted content

Our Service is intended exclusively for individuals who are 18 years of age or older. The Service is not directed to minors and may not be accessed or used by anyone under the age of 18.

By creating an account, accessing, or using the Service, you represent and warrant that you are at least 18 years old (or the age of legal majority in your jurisdiction, if higher).

No сollection of data from minors. We do not knowingly collect, solicit, or process personal data from individuals under 18 years of age. The Service is not intended for children under 13 and is not directed to children within the meaning of the U.S. Children’s Online Privacy Protection Act (COPPA).

If we become aware that we have collected personal data from an individual under 18, we will take appropriate steps to:

  • suspend, disable, or terminate the account;
  • restrict access to the Service;
  • delete or anonymize the associated personal data, unless retention is required by law

Age verification and enforcement. We may implement age-gating measures, require date-of-birth confirmation, or request additional age verification data where necessary to enforce this policy, comply with applicable law, or protect the integrity of the Service.

If a user fails to provide satisfactory age verification when requested, we reserve the right to deny access, suspend, or permanently terminate the account.

California residents. Consistent with the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), we do not knowingly sell or share personal data of consumers under 18 years of age. Because our Service is restricted to adults only, we do not permit minors to create accounts or use the Service.

Parental сontact. If you are a parent or legal guardian and believe that a person under 18 has created an account or provided personal data to us, please contact us at [email protected]. We will promptly investigate and take appropriate action.

Use of Google OAuth API

We use the Google OAuth API as an optional authentication method to allow users to create and access their accounts securely and efficiently.

When you choose to sign in using Google OAuth or link your Google account to our Service, we receive only the following personal data, subject to your Google account settings and consent:

  • email address;
  • profile name.

We do not access your Google password or any other Google account data.

Data obtained via Google OAuth is used solely for:

  • creating and managing your account;
  • enabling authentication-based features;
  • communicating with you regarding account-related matters;
  • ensuring platform security and preventing abuse.

Google acts as an independent data controller with respect to data processed through Google OAuth. Processing by Google is governed by Google’s own privacy policies.

You may disconnect your Google account at any time via your account settings. Disconnecting does not automatically delete personal data already processed by us. Data deletion requests may be submitted in accordance with this Privacy Policy.

Age restriction. Social login is available only to users who meet the applicable minimum age requirements described in the “Children and age-restricted content” section and our Terms.

Processing of personal data in connection with social login features is based on the legal grounds described in the “Legal basis for processing personal data (EU/EEA)” section below.

Use of Facebook Login

We offer Facebook Login as an optional authentication method. When you choose to use Facebook Login, we may receive the following personal data, subject to your Facebook privacy settings:

  • email address;
  • profile name.

We do not receive access to your Facebook password or private messages.

Meta Platforms, Inc. acts as an independent data controller for personal data processed through Facebook Login.

Facebook Login is available only to users who meet the minimum age requirements set out in our Terms of Use.

Age restriction. Social login is available only to users who meet the applicable minimum age requirements described in the “Children and age-restricted content” section and our Terms.

Processing of personal data in connection with social login features is based on the legal grounds described in the “Legal basis for processing personal data (EU/EEA)” section below.

How do we use your personal data?

General principles. We process personal data solely to the extent necessary to provide, operate, secure, and improve the Service, to manage subscriptions and Coins, to process payments, and to comply with applicable legal obligations.

Each category of personal data described in the section “Types of personal data we collect” is processed only for the specific purposes outlined below and in accordance with applicable data protection laws, including the GDPR and relevant U.S. privacy regulations.

A. Provision and operation of the Service

We use personal data to:

  • create, authenticate, and manage user accounts;
  • grant and manage access to digital comics and related content;
  • provide access to subscription-based features and Coins functionality;
  • maintain user preferences and account settings.

This processing is necessary for the performance of the contract between you and Comicrush.

B. Subscriptions, Coins, and payments

Personal data is used to:

  • process subscription purchases and renewals;
  • credit, manage, and track Coin balances;
  • process refunds, chargebacks, and transaction-related inquiries;
  • prevent payment fraud and abuse.

Payment processing is performed by third-party payment service providers. Comicrush does not collect or store full payment card details and does not act as a data controller in respect of such data.

Third-party payment service providers act as independent data controllers or data processors in accordance with their own privacy policies. Comicrush processes only limited transaction-related data necessary for accounting, fraud prevention, and customer support purposes.

C. Service improvement, analytics, and functionality

We use technical and usage data to:

  • analyze how users interact with the Service;
  • improve performance, usability, and content availability;
  • detect errors, troubleshoot issues, and optimize features.

Analytics data is used in aggregated or pseudonymized form where possible and is processed in accordance with applicable law.

Where required by applicable law (including EU law), analytics and measurement technologies are used only with user consent, which may be withdrawn at any time.

D. Security, fraud prevention, and abuse detection

We process personal data to:

  • detect, prevent, and investigate fraud, including misuse of Coins, subscription abuse, or unauthorized access;
  • protect the security and integrity of the Service;
  • ensure compliance with legal and regulatory requirements.

Such processing is based on our legitimate interest in maintaining a secure and lawful platform.

E. Communications and customer support

We use your personal data to:

  • send transactional communications (such as purchase confirmations, subscription updates, and account notifications);
  • respond to support requests and inquiries;
  • notify you of important changes to our Terms, Privacy Policy, or Service functionality.

Marketing communications related to our own Service (such as subscription offers or new content releases) are sent only where permitted by applicable law and subject to your consent or opt-out preferences. We do not share personal data with third parties for their own direct marketing purposes without your explicit consent.

You may opt out of non-essential communications at any time using the unsubscribe mechanisms provided or through your account settings.

F. Cookies and similar technologies

We use cookies and similar technologies to:

  • enable core website functionality;
  • support authentication and security;
  • remember user preferences;
  • analyze usage and improve the Service.

Where required by law, non-essential cookies are used only with your consent, which you may withdraw at any time.

For more detailed information about the types of cookies we use and your choices, please refer to our Cookie Policy.

G. Legal compliance and enforcement

We may process personal data to:

  • comply with applicable laws, regulations, and legal obligations;
  • respond to lawful requests from authorities;
  • exercise or defend legal claims;
  • enforce our Terms and Conditions.

With whom we may share your personal data

We may share your personal data only where necessary and in accordance with applicable data protection laws. We do not sell personal data for monetary consideration. We may disclose personal data to third parties for advertising and measurement purposes through cookies, pixels, SDKs, or similar tracking technologies. Under California law, certain such disclosures may be considered “sharing” for cross-context behavioral advertising, even if no money is exchanged. California residents may opt out at any time as described in the “Do Not Sell or Share My Personal Data (California residents)” section below.

We may disclose your personal data to the following categories of recipients:

A. Service providers

We may share your personal data with trusted third-party service providers who perform services on our behalf and under our instructions. These providers are contractually obligated to process personal data only for specified purposes and to implement appropriate technical and organizational security measures.

Such service providers may include:

  • Payment processors (to process subscription payments and Coin purchases);
  • Cloud computing and hosting providers;
  • Data storage providers;
  • Analytics service providers (for platform performance analysis and usage statistics);
  • User account registration and authentication services;
  • Customer support service providers;
  • Advertising and ad network providers (where applicable);
  • Affiliate marketing program providers.

These providers process personal data strictly as data processors and only to the extent necessary to provide their services.

B. Content partner studios (Aggregated and anonymized data)

We collaborate with third-party studios and content creators who produce comics and digital content available on our platform.

Where required under arrangements, we may share:

  • aggregated,
  • statistical,
  • fully anonymized,
  • non-identifiable

data relating to content consumption, such as:

  • number of views,
  • reading duration,
  • engagement metrics,
  • purchase statistics (subscription/Coins related to specific content).

Such data does not contain any personal data and does not allow the identification of individual users.

We do not share identifiable user data (such as name, email, payment details, IP address, or account identifiers) with content partner studios.

C. Business transfers

If Comicrush is involved in a merger, acquisition, restructuring, asset sale, financing transaction, or change of control, your personal data may be transferred as part of that transaction.

In such cases:

  • personal data will remain subject to confidentiality obligations;
  • we will provide notice before personal data becomes subject to a different Privacy Policy.

D. Legal and regulatory requirements

We may disclose personal data where required to do so by law or in response to valid and lawful requests by public authorities (e.g., courts, regulatory authorities, or government agencies).

E. Protection of rights and legal claims

We may disclose personal data where we believe in good faith that such disclosure is necessary to:

enforce our Terms;

  • protect and defend the rights, property, or security of Comicrush;
  • prevent fraud, abuse, unauthorized access, or misuse of the platform;
  • protect the safety of users or the public;
  • establish, exercise, or defend legal claims.

How long do we keep your personal data?

We retain personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy, including providing the Service, managing subscriptions and Coins, processing payments, ensuring security, and complying with legal obligations.

Retention periods depend on the type of data and the applicable legal requirements:

  1. Account data. We retain account-related personal data (such as email address and account credentials) for as long as your account remains active. If you delete your account, we will delete or anonymize your personal data within a reasonable period, unless retention is required by law.
  2. Subscription and transaction data. Transaction records, billing data, and related payment metadata are retained for the period required under applicable accounting, tax, and regulatory laws (which may typically range from 5 to 10 years, depending on jurisdiction).
  3. Coin balances and purchase history. Data relating to Coin purchases and usage is retained for as long as necessary to administer your account and comply with financial and fraud-prevention obligations.
  4. Usage and technical data. Usage Data and technical logs are generally retained for a limited period necessary for analytics, performance optimization, and security purposes. Security-related logs may be retained longer where necessary to prevent fraud or investigate misuse of the Service.
  5. Customer support communications. Support inquiries and related correspondence may be retained for a reasonable period to resolve disputes, enforce our agreements, or comply with legal obligations.

When retention is no longer necessary, we will delete or anonymize the personal data, unless continued retention is required or permitted by law.

You may have the right to request deletion of your personal data, subject to certain legal limitations.

What is our stance on third-party websites?

Our Service may contain links to third-party websites, services, or applications that are not owned or controlled by Comicrush.

We are not responsible for the privacy practices, content, or security of such third-party services. The inclusion of a link does not imply endorsement or affiliation.

If you choose to visit or interact with any third-party website or service, your personal data will be governed by that third party’s privacy policy and terms.

We encourage you to review the privacy policies of any third-party services before providing them with your personal data.

Transfer of personal data

We may store and process your personal data in the European Economic Area (EEA), the United States, or other jurisdictions where our service providers operate.

If you access the Service from outside the country where our servers or service providers are located, your personal data may be transferred to and processed in another country that may have different data protection laws than those of your jurisdiction.

Where required by applicable data protection laws (including the GDPR), we implement appropriate safeguards to ensure that personal data transferred outside the EEA or other protected jurisdictions is adequately protected. Such safeguards may include:

  • Standard Contractual Clauses approved by the European Commission;
  • transfers to countries recognized as providing an adequate level of data protection;
  • other lawful transfer mechanisms as required under applicable law.

By using the Service, you acknowledge that your personal data may be transferred and processed in accordance with this Privacy Policy.

Security of the personal data

We implement appropriate technical and organizational security measures designed to protect your personal data against unauthorized access, alteration, disclosure, or destruction.

Such measures may include:

  • encryption of data in transit (e.g., SSL/TLS);
  • access control mechanisms;
  • secure hosting infrastructure;
  • internal data access limitations;
  • monitoring and fraud-prevention tools.

However, no method of transmission over the Internet or electronic storage is completely secure. While we strive to protect your personal data, we cannot guarantee absolute security.

If you believe that your account or personal data has been compromised, please contact us immediately at [email protected].

Changes to Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in legal requirements, technical developments, or our data processing practices.

If we make material changes, we will:

  • update the “Effective date” at the top of the Privacy Policy;
  • where required by law, provide notice via the Website or by email.

Continued use of the Service after the updated Privacy Policy becomes effective constitutes your acknowledgment of the changes.

Terms related to EU/EEA users

Legal basis for processing personal data

If you are located in the European Union (EU) or the European Economic Area (EEA), we process your personal data only where we have a valid legal basis under the General Data Protection Regulation (GDPR).

Depending on how you use the Service, our legal bases include:

A. Performance of a contract

We process your personal data where it is necessary to perform our contract with you or to take steps at your request prior to entering into a contract. This includes processing necessary to:

  • create and manage your user account;
  • provide access to digital comics and subscription features;
  • process purchases of Subscriptions or Coins;
  • manage your Coins balance and transaction history;
  • provide customer support;
  • send transactional communications (e.g., payment confirmations, subscription updates);
  • ensure the technical functionality and security of the Service.

If you do not provide certain required personal data, we may be unable to provide paid features or access to the Service.

B. Legitimate interests

We process personal data where necessary for our legitimate interests, provided that such interests are not overridden by your fundamental rights and freedoms.

Where we rely on legitimate interests as a legal basis, we have conducted an assessment to ensure that our interests are not overridden by your fundamental rights and freedoms. You may request further information about this assessment by contacting us.

Our legitimate interests may include:

  • improving and developing the Service;
  • analyzing usage patterns and engagement with comics and features;
  • ensuring platform security and fraud prevention;
  • enforcing our Terms and protecting our legal rights;
  • internal business administration;
  • direct marketing of our own similar services (where permitted by applicable law).

You have the right to object to processing based on legitimate interests at any time.

C. Consent

We rely on your consent where required by law, including for:

  • sending marketing communications where prior consent is required;
  • placing non-essential cookies or using similar tracking technologies;
  • processing optional profile data;
  • enabling certain third-party integrations (e.g., social login features).

You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

D. Legal obligations

We may process your personal data where necessary to comply with applicable legal obligations, including:

  • accounting and tax requirements;
  • fraud prevention and anti-money laundering obligations;
  • responding to lawful requests from public authorities;
  • maintaining required records.

Summary of purposes and legal bases (EU/EEA)

  • Account creation, Subscriptions, Coins, and access to content: performance of a contract.
  • Payments, accounting, fraud prevention, chargebacks: legal obligations and legitimate interests (fraud prevention and platform integrity).
  • Security monitoring and abuse detection: legitimate interests (security, fraud prevention, and protection of users and the Service).
  • Analytics (where consent is required): consent; otherwise legitimate interests (service improvement).
  • Marketing communications: consent where required; otherwise legitimate interests for marketing similar services, subject to opt-out.
  • Non-essential cookies/pixels/SDKs (including third-party advertising or measurement tags): consent, where required under applicable EU/EEA law.

Automated decision-making

We do not use automated decision-making (including profiling) that produces legal or similarly significant effects on users. We may use automated processing for content recommendations and service personalization; however, such processing does not produce legal or similarly significant effects.

If we introduce automated decision-making that produces legal or similarly significant effects in the future, we will update this Privacy Policy and provide the safeguards required under Article 22 GDPR.

Additional information for EU/EEA users

Where we rely on contractual necessity, providing personal data is typically a contractual requirement necessary to access paid features (Subscriptions and Coins).

Where processing is based on legal obligations, providing data may be a statutory requirement.

Where processing is based on consent, providing personal data is voluntary, and you may withdraw consent at any time.

If you have questions regarding the specific legal basis applicable to a particular processing activity, you may contact us at [email protected].

Your rights as a data subject

We respect your privacy rights and are committed to ensuring that you can exercise your rights under applicable data protection laws, including the GDPR (for EU/EEA users).

Depending on your location and applicable law, you may have the following rights:

A. Right of access

You have the right to request confirmation as to whether we process your personal data and, if so, to obtain access to such data and receive a copy of it.

This includes information about:

  • the purposes of processing;
  • categories of personal data concerned;
  • recipients or categories of recipients;
  • retention periods;
  • your rights under applicable law.

B. Right to rectification

You have the right to request correction of inaccurate or incomplete personal data we hold about you.

Certain account data may be updated directly through your account settings.

C. Right to erasure (“Right to be forgotten”)

You have the right to request deletion of your personal data where:

  • the data is no longer necessary for the purposes collected;
  • you withdraw consent, and no other legal basis applies;
  • you successfully object to processing;
  • the data has been unlawfully processed.

Please note that we may retain certain data where required by law, including for:

  • tax and accounting obligations;
  • fraud prevention;
  • dispute resolution;
  • enforcement of our Terms.

Deletion of your account may result in the loss of access to Subscriptions, Coins balances, and purchased content.

D. Right to restrict processing

You may request that we restrict processing of your personal data where:

  • you contest its accuracy;
  • processing is unlawful, but you oppose erasure;
  • we no longer need the data, but you require it for legal claims;
  • you object to processing pending verification.

E. Right to data portability

Where processing is based on consent or contract and carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller.

F. Right to object

You have the right to object to processing based on legitimate interests.

You also have the right to object at any time to processing for direct marketing purposes.

G. Right to withdraw consent

Where processing is based on your consent (e.g., marketing communications or non-essential cookies), you may withdraw your consent at any time.

Withdrawal does not affect the lawfulness of processing prior to withdrawal.

H. Right to lodge a complaint

You have the right to lodge a complaint with the supervisory authority in the EU Member State of your habitual residence, place of work, or place of the alleged infringement.

How to exercise your rights

To exercise your rights, please contact us at: [email protected].

We may need to verify your identity before processing your request to ensure the security of your personal data.

No fee

You will not normally have to pay a fee to exercise your rights. However, we may charge a reasonable fee or refuse to act on a request if it is manifestly unfounded, excessive, or repetitive.

Response time

We aim to respond to all legitimate requests within one (1) month. If your request is complex or involves multiple requests, we may extend this period by up to two additional months, in which case we will inform you accordingly.

Terms related to residents of Canada (PIPEDA)

Accountability

Comicrush is responsible for personal data under its control and has designated an individual responsible for privacy compliance. You may contact us at [email protected] regarding privacy-related inquiries.

Legal basis and consent (Canada)

If you are a resident of Canada, we collect, use, and disclose your personal data in accordance with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA).

We collect, use, and disclose personal data for the purposes described in this Privacy Policy, and only to the extent a reasonable person would consider appropriate in the circumstances, in accordance with PIPEDA.

Consent

Under Canadian privacy laws, we generally rely on your consent to collect, use, or disclose your personal data.

Consent may be:

  • express, for example, when you actively agree to this Privacy Policy or opt in to receive marketing communications; or
  • implied, where your actions reasonably indicate consent, such as creating an account, purchasing a subscription, or using the Service.

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal of consent may affect our ability to provide certain features of the Service (including account access, Subscriptions, or Coins functionality).

To withdraw consent or make an inquiry regarding your personal data, you may contact us at: [email protected].

Marketing communications are sent only where permitted by applicable Canadian anti-spam laws (including CASL), and you may unsubscribe at any time using the unsubscribe link provided in such communications.

Safeguards

We protect personal data using security measures appropriate to the sensitivity of data, as described in the “Security of personal data” section of this Privacy Policy.

Access and сorrection

You may request access to the personal data we hold about you and request corrections, subject to limited exceptions permitted by law. To submit an access or correction request, contact us at [email protected].

We will respond within the time limits required by applicable Canadian law and generally within 30 days, subject to permitted extensions.

Complaints

If you have concerns about our compliance with PIPEDA, you may file a complaint with the Office of the Privacy Commissioner of Canada (OPC). We encourage you to contact us first so we can address your concern.

You may also contact us at [email protected] so we can address your concern before you escalate it to the OPC.

Processing without consent

In limited circumstances, we may collect, use, or disclose personal data without consent where permitted or required by applicable law, including where:

  • required to comply with a court order, subpoena, or other lawful authority;
  • necessary to investigate fraud, payment abuse, security incidents, or violations of our Terms;
  • required to respond to legal claims or regulatory obligations;
  • necessary to protect the rights, safety, or security of Comicrush, users, or the public.

We do not use personal data for purposes unrelated to those identified at the time of collection without obtaining additional consent where required by law.

Cross-border transfers

Your personal data may be transferred to service providers located outside Canada, including in the United States or the European Union. Such data may be subject to foreign laws and accessible to foreign authorities. We take reasonable steps to ensure that appropriate safeguards are in place.

U.S. State privacy rights (other states)

Depending on your U.S. state of residence, you may have rights to access, delete, correct, or opt out of certain processing, such as targeted advertising. To submit a request, contact us at [email protected]. We will process requests in accordance with applicable state law and may need to verify your identity before responding.

Privacy Notice for California and Virginia Residents

This section applies solely to residents of California (under the California Consumer Privacy Act, as amended by the California Privacy Rights Act - “CCPA/CPRA”) and residents of Virginia (under the Virginia Consumer Data Protection Act - “VCDPA”).

Notice at сollection (California residents)

At or before the point of collection, California residents are informed that we collect the categories of personal data described below for the purposes described in this Privacy Policy. We retain personal data for the periods described in the “How long do we keep your personal data?” section.

Categories of personal data collected

In the preceding twelve (12) months, we have collected the following categories of personal data as defined under applicable U.S. privacy laws:

A. Category A - Identifiers

Examples: email address, online identifier, account name, IP address.

Collected: Yes.

B. Category B - Personal data under Cal. Civ. Code § 1798.80(e)

Examples:

  • name or email address provided in connection with account registration;
  • limited payment-related data (e.g., transaction identifiers, billing country, first six and last four digits of a payment card, where permitted).

We do not collect Social Security numbers, driver’s license numbers, passport numbers, full financial account numbers, or health data.

Collected: Yes (limited to account and limited transaction data).

C. Category D - Commercial data

Examples:

  • Subscription purchases;
  • Coin purchases;
  • transaction history;
  • records of digital content accessed or purchased.

Collected: Yes.

D. Category F - Internet or other electronic network activity

Examples:

  • interaction with the Website;
  • pages viewed;
  • features used;
  • reading duration;
  • device and browser data.

Collected: Yes.

E. Category G - Approximate geolocation data

Examples:

  • country or region inferred from IP address.

We do not collect precise GPS location data.

Collected: Yes (approximate only).

Categories not collected

We do not collect:

  • biometric data;
  • professional or employment-related data;
  • non-public education data;
  • genetic or health data;
  • sensitive personal data such as Social Security numbers or precise geolocation;
  • protected classification characteristics (e.g., race, religion, sexual orientation);
  • inferences used to create behavioral or psychological profiles;
  • sensitive personal data (CPRA).

Sensitive personal data (CPRA)

We collect limited sensitive personal data (account login credentials) solely for account authentication and security purposes. We do not use sensitive personal data for profiling or inference purposes.

Sources of personal data

We collect personal data:

  • directly from you (when you create an account or purchase a Subscription or Coins);
  • automatically through your interaction with the Service (cookies, analytics, usage data);
  • from payment processors (limited transaction confirmation data only).

Retention (California and Virginia)

We retain personal data for the periods described in the “How long do we keep your personal data?” section of this Privacy Policy, including: account data (for the life of the account), transaction records (typically 5–10 years for accounting and tax compliance), and technical/security logs (for a limited period, longer where needed for fraud prevention or investigations).

Use of personal data

We may use or disclose personal data we collect for “business purposes” or “commercial purposes” (as defined under CCPA and CPRA), and other applicable U.S. privacy laws, including the following:

1. Provision and operation of the service

To operate, maintain, and provide our online comics platform, including:

  • creating, authenticating, and managing user accounts;
  • granting and managing access to digital comics and subscription-based content;
  • managing Coin balances and related functionality;
  • maintaining user preferences and account settings.

2. Processing subscriptions and Coin purchases

To process Subscription payments and Coin purchases, including:

  • facilitating transactions through third-party payment processors;
  • managing renewals, refunds, chargebacks, and billing inquiries;
  • maintaining transaction records for accounting and legal compliance.

3. Customer support and communications

To provide customer support and respond to inquiries, including:

  • investigating and addressing user concerns;
  • providing technical assistance;
  • sending transactional communications such as purchase confirmations, subscription updates, and service-related notices.

4. Security and fraud prevention

To detect, investigate, and prevent security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including:

  • monitoring usage patterns;
  • preventing unauthorized access;
  • enforcing our Terms and policies;
  • protecting the rights, property, and safety of Comicrush and users.

5. Internal operations and Service improvement

For internal administrative, auditing, research, analytics, and quality assurance purposes, including:

  • analyzing usage trends;
  • improving platform functionality and content delivery;
  • enhancing user experience.

6. Legal compliance

To comply with applicable laws, regulations, court orders, or lawful governmental requests.

7. Corporate transactions

To evaluate or conduct a merger, acquisition, restructuring, asset sale, financing transaction, or other corporate transaction, where personal data may be transferred as part of the transaction, subject to applicable confidentiality obligations.

8. Additional purposes

As described to you at the time of collection or otherwise permitted by applicable law.

If we collect additional categories of personal data or use personal data for materially different, unrelated, or incompatible purposes, we will update this Privacy Policy accordingly.

Sharing of personal data

We may disclose personal data to third parties for business purposes, as permitted under applicable U.S. privacy laws, including the CCPA, as amended by the CPRA, and VCDPA.

We do not sell personal data for monetary consideration.

Where we disclose personal data to service providers, contractors, or other third parties for business purposes, we enter into contractual agreements that:

  • limit the use of personal data to specified purposes;
  • prohibit retention, use, or disclosure of personal data for any purpose other than those specified in the contract;
  • require the implementation of appropriate technical and organizational safeguards;
  • prohibit the recipient from selling or sharing personal data except as permitted by law.

We may disclose personal data to the following categories of recipients:

1. Service providers and contractors

Third parties that process personal data on our behalf and under our instructions, including:

  • payment processors (for subscription and Coin transactions);
  • cloud hosting and infrastructure providers;
  • data storage providers;
  • analytics providers;
  • customer support providers;
  • authentication and account management service providers.

These entities process personal data solely for business purposes and pursuant to written agreements.

2. Business partners (limited scope)

Where necessary to operate the Service, we may disclose limited data to business partners involved in platform operations.

For example, content partner studios may receive aggregated, anonymized, and non-identifiable usage statistics for revenue-sharing verification purposes.

We do not share identifiable user data (such as name, email address, payment details, IP address, or account credentials) with content partners for their own independent use.

3. Corporate transaction participants

In connection with a merger, acquisition, restructuring, financing, or sale of assets, personal data may be transferred subject to confidentiality obligations and applicable legal requirements.

4. Legal and regulatory authorities

We may disclose personal data where required by law or in response to lawful requests by public authorities, courts, or regulators.

5. Other disclosures at your direction

We may disclose personal data to third parties where you direct us to do so or authorize such disclosure.

Disclosure of personal data for business purposes

In the preceding twelve (12) months, we have disclosed the following categories of personal data for business purposes:

  • Identifiers (Category A): disclosed to payment processors, cloud hosting providers, authentication providers.
  • Commercial data (Category D): disclosed to payment processors and accounting service providers.
  • Internet or electronic network activity (Category F): disclosed to analytics providers.
  • Approximate geolocation data (Category G): disclosed to hosting and analytics providers.

We do not sell personal data for monetary consideration.

Sale or sharing of personal data (California residents)

Under the CCPA, as amended by the CPRA, “sale” means disclosing personal data to a third party for monetary or other valuable consideration.

Based on our current business practices, we do not sell personal data for monetary consideration.

We do not knowingly sell or share personal data of consumers under 16 years of age. Our Service is restricted to adults (18+), and we do not permit minors to create accounts or use the Service.

Children

Please see the “Children and age-restricted content” section of this Privacy Policy for our age-gating approach and children’s privacy practices, including our 18+ age-gating and enforcement practices, and COPPA-related protections applicable in the event we become aware of data collected from a child.

Do not sell or share my personal data (California residents)

We do not sell personal data for monetary consideration. However, under the CPRA, certain disclosures of personal data to third parties for cross-context behavioral advertising (for example, through third-party cookies, pixels, SDKs, or similar tracking technologies) may be considered “sharing,” even if no money is exchanged.

California residents have the right to opt out of the “sale” or “sharing” of their personal data for cross-context behavioral advertising at any time by:

  • adjusting their Cookie Settings to disable “Marketing” cookies (and, if desired, “Analytics” cookies); or
  • contacting us at [email protected].

We also honor opt-out preference signals where detected, including the Global Privacy Control (GPC), in accordance with applicable California law.

Your rights under California and Virginia privacy laws

If you are a resident of California or Virginia, you may have certain rights under applicable state privacy laws, including the CCPA, as amended by the CPRA, and the VCDPA.

These rights apply only to residents of those states.

1. Right to know/right to access

You have the right to request that we disclose:

  • the categories of personal data  we collect about you;
  • the categories of sources from which the personal data is collected;
  • the business or commercial purposes for collecting or processing the data;
  • the categories of third parties with whom we share personal data;
  • the specific pieces of personal data we have collected about you.

We will verify your request before providing a response.

2. Right to correct

You have the right to request correction of inaccurate personal data that we maintain about you, taking into account the nature of the data and the purposes of processing.

3. Right to delete

You have the right to request deletion of your personal data, subject to certain exceptions.

We may deny deletion where retention is necessary to:

  • complete a transaction (such as processing a Subscription or Coin purchase);
  • detect or prevent fraud or security incidents;
  • comply with legal obligations;
  • exercise or defend legal claims;
  • maintain internal records reasonably aligned with your relationship with us.

4. Right to opt out of sale or sharing (California residents)

We do not sell personal data for monetary consideration. You may exercise your right to opt out of the sale or sharing of your personal data for targeted advertising by:

  • adjusting your Cookie Settings to disable “Marketing” cookies (and, if desired, “Analytics” cookies); or
  • contact us at [email protected].

We may need to verify your identity before processing requests submitted via email, in accordance with applicable law.

5. Right to opt out of targeted advertising and profiling (Virginia residents)

Virginia residents have the right to opt out of:

  • targeted advertising;
  • the sale of personal data;
  • profiling in furtherance of decisions that produce legal or similarly significant effects.

Our Service does not use profiling that produces legal or similarly significant effects.

Requests may be submitted at: [email protected].

6. Right to appeal (Virginia residents)

If we decline to take action regarding your request, you have the right to appeal our decision. You may submit an appeal by contacting us at [email protected].

We will respond to your appeal within 60 days as required by Virginia law. If we deny your appeal, we will provide you with information about how to contact the Virginia Attorney General to submit a complaint.

To appeal, email us at [email protected] with the subject line “Virginia Privacy Appeal”.

7. Right to limit use of sensitive personal data (California residents)

We do not use or disclose sensitive personal data beyond what is reasonably necessary to provide the Service.

If we collect sensitive personal data (as defined under CPRA), California residents may request that we limit its use to what is necessary to perform the requested services.

8. Right to non-discrimination

We will not discriminate against you for exercising your privacy rights. This means we will not:

  • deny you goods or services;
  • charge different prices or rates;
  • provide a different level or quality of service.

However, certain features of the Service (such as Subscription access) may depend on the data necessary to provide them.

How to exercise your rights

To exercise your rights, please contact us at [email protected].

We will respond within the timeframe required by applicable law.

We may need to verify your identity before processing your request.

You may designate an authorized agent to submit requests on your behalf. We may require proof that the authorized agent is authorized to act on your behalf and may also require you to verify your identity directly with us.

Response timing

We will respond to verifiable consumer requests within the timeframes required by applicable law. Where permitted, we may extend the response period when reasonably necessary and will inform you of any extension.

Do not track signals (CalOPPA)

Under the California Online Privacy Protection Act (CalOPPA), we are required to disclose how we respond to “Do Not Track” (“DNT”) browser signals.

Currently, our Website does not respond to DNT signals. There is no uniform industry standard for recognizing or responding to DNT signals.

However, where required by applicable state privacy laws (including California law), we recognize and respond to legally valid opt-out preference signals, such as the Global Privacy Control (GPC). We honor Global Privacy Control (GPC) signals where detected, in accordance with applicable California law.

Additional California privacy rights (“Shine the Light”)

California Civil Code § 1798.83 (the “Shine the Light” law) allows California residents to request certain data regarding our disclosure of personal data to third parties for their own direct marketing purposes.

We do not disclose personal data to third parties for their own direct marketing purposes without your consent.

If you are a California resident and wish to make an inquiry under this law, you may contact us at [email protected].