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COMICSPRING PRIVACY POLICY

This Privacy Policy shall constitute an integral part of the Terms of Service of Comicspring Platform dated 29/09/2016 (Terms of Service). Definitions of the terms used in this Privacy Policy have been included in the Terms of Service. The provisions of the Terms of Service shall be applied accordingly.

1. PERSONAL DATA

1.1. Personal data provided by the User shall be processed by Comicspring (i.e. COMICSPRING—Michal Klimczyk, ul. Golikówka 33A, 30-723 Kraków, NIP: 679-279-54-02, REGON: 362521218), which is the Personal Data Controller within the meaning of the Data Protection Act of 29 August 1997. You may contact us in particular via e-mail at the following e-mail address: hello@comicspring.com.

1.2. The scope of the processed personal data shall be determined by the scope of data completed by the User and subsequently sent to us by means of a relevant form. Processing the personal data may pertain to User’s e-mail address, first and last name, and computer IP address. Comicspring guarantees that the processing of personal data shall take place in accordance with and upon the terms prescribed in the content of GENERAL DATA PROTECTION REGULATION (Regulation (EU) 2016/679).

1.3. User’s personal data shall be processed for the following purposes: (a) creation of the Account, provision of services by electronic means, examination of filed complaints and other actions as specified in the Terms of Service; (b) possible promotional and commercial actions of Comicspring; (c) settlement of disputes; (d) evaluation of the interest in Comicspring services; (e) in the case of having Users’ express consents—for the purpose of notifying the Users on services and updates; (f) implementation of the applicable legal provisions; (h) prevention of potentially prohibited or illegal actions, and enforcement of the Agreement. Comicspring guarantees that only persons authorized by Comicspring to administer the IT system on the basis of granted authorisations which include confidentiality statements in the scope of processing data and relevant safeguards shall have access to Users’ personal data.

1.4. Provision of the personal data by the User shall be voluntary, but the lack of consent to process personal data marked as obligatory shall prevent Comicspring from performing services and agreements.

1.5. The legal basis for processing User’s personal data in the case referred to in clause 1.3 is the statutory authorization to process data which are essential to act in accordance with the law, as well as the statutory authorization to process data which are necessary to perform an agreement if the data subject is a party to such agreement, or if it is essential for undertaking certain actions prior to conclusion of an agreement upon request of the data subject, and a voluntary consent of the User.

1.6. User’s personal data shall only be transferred for the purpose of performing agreements for provision of services by electronic means by Comicspring to a hosting company providing services to Comicspring. An entity to which Comicspring transfers personal data for processing on the basis of a personal data transfer agreement (hereinafter referred to as Transfer Agreement) shall guarantee an adequate level of security and confidentiality of the processing of personal data. Comicspring shall, within the frames of the Transfer Agreement, transfer Users’ personal data for processing only to entities observing the applicable corporate rules or holding relevant certificates. An entity processing User’s personal data on the basis of the Transfer Agreement through another entity shall proceed only on the basis of prior written consent given by Comicspring. The personal data collected by Comicspring may also be disclosed to: competent state bodies upon their request on the basis of relevant provisions of law, or other persons and entities—in the cases prescribed in the provisions of law. This shall not apply to cases when personal data are processed by third parties for marketing and advertising purposes and the processing requires express/separate consent of the User.

1.7. Disclosing User’s personal data to unauthorized entities under this Privacy Policy may only take place upon User’s prior consent.

1.8. The User shall have the right to control the process of data which refer to him/her, and which are collected in databases; in particular, he/she shall have the right to: (a) access the content of his/her data and correct them through filing a relevant request with Comicspring; (b) demand temporary or permanent suspension of their processing, or their deletion if they are incomplete, invalid, inaccurate, or if they have been collected in violation of the act, or they have become unnecessary for realization of the purpose for which they had been collected; (c) raise an objection against processing his/her personal data—in other cases as prescribed by the law—and the right to demand their deletion if they have become unnecessary for realization of the purpose for which they had been collected. The User shall have the right to request Comicspring to delete the collected personal data referring to him/her, both from the system belonging Comicspring as well as from bases of entities which have co-operated with Comicspring, to restrict the processing of data and the moving of the personal data collected by Comicspring and referring to him/her, in this to receive them in a structured form, to file a complaint to the supervising body if the User finds that his/her data are processed in violation of the law, and to lodge legal remedies before a court against the supervising body and the entity committing the violations.

1.9. If Comicspring is advised that the User uses the service provided by electronic means in a way violating the Terms of Service or applicable provisions of law (unauthorized use), then Comicspring may process User’s personal data in the scope required for establishing his/her liability. Comicspring may also disclose User’s data for the purposes related to the law, protection, and security. 

1.10. User’s data may be processed in an automated manner in the form of profiling, which shall consist in creation of dynamic contact forms on the website, dynamic and automated messages and advertising content, after-sales communication, contact segmentation and sending of e-mail messages, reminders on an abandoned cart, automatic selection of communication channels, contact management, and which shall result in generation of personalised marketing actions by Comicspring. 2. OTHER DATA

2.1. The Platform may store http enquiries, therefore the files containing web server logs may store certain data, including the IP address of the computer sending the enquiry, the name of User’s station—identification through http protocol, if possible—date and system time of registration on the Platform and receipt of the enquiry, number of bytes sent by the server, the URL address of the site visited by the User before if the User has entered the Platform through a link, information concerning User’s browser, information concerning errors occurred by realization of the http transaction. Web server logs may be collected for the purpose of proper administration of the Platform. Only persons authorized to administer the IT system shall have access to the data. The files containing web server logs may be analyzed for the purposes of preparing statistics concerning traffic on the Platform and occurring errors. Summary of such details shall not identify Users.

3. INFORMATION SECURITY

3.1. User’s personal data are stored and secured in accordance with the rules as prescribed by the applicable legal provisions. Comicspring shall apply technological and organizational means in order to secure the process of the personal data corresponding to the threats and category of data to be secured; in particular through technical and organizational means Comicspring shall secure the data against being published to unauthorized persons, taken over by an unauthorized person, processed in violation of the law and changed, lost, damaged or destroyed. The Users’ personal data shall be collected and stored on a secured server, moreover, the data shall be secured by Comicspring’s internal procedures related to the process of personal data and information security policy. Comicspring uses the secure socket layer (SSL) technology, which is designed to encrypt the transmission of information exchanged between User’s browser and Comicspring’s website.

3.2. In order to log in to the Account, it shall be necessary to provide a relevant username and password. In order to ensure an appropriate level of security, the password for the Account shall exist only in an encrypted form. 

3.3. At the same time, Comicspring states that using the Internet and services provided by electronic means poses a threat of malware breaking into User’s teleinformatic system and device, as well as of an unauthorized access to User’s data, including personal data, by third parties. Nevertheless, this shall not release Comicspring from the obligation to introduce all necessary system security means in a manner ensuring security of the processing of Users’ personal data and protection against incidents connected with violation of security of the personal data processing. In order to minimize such threats, the User shall use appropriate technical security means, e.g. using updated antivirus programs or programs securing identification of the User in the Internet. In order to obtain detailed and professional information related to the security in the Internet, Comicspring recommends taking advice from entities specializing in such IT services.

3.4. Comicspring declares to have in place and to introduce all necessary technical means as prescribed in Articles 25, 30, 32–34, 35–39 GDPR (GENERAL DATA PROTECTION REGULATION (Regulation (EU) 2016/679) which provide for enhanced protection and security of the processing of Users’ personal data, including anonymisation and pseudonymisation of data, and technical solutions which enable it to keep the ability to provide for continuous confidentiality, integrity, accessibility, resilience of the personal data processing systems and services and the ability to quickly restore accessibility of personal data and access to them in the case of a physical or technical incident.

4. COOKIES

4.1. For the purposes of a correct operation of the Platform, Comicspring uses Cookies support technology. Cookies are packages of information stored on the User’s device through the website, usually containing information corresponding to the intended use of a particular file, by means of which the User uses the website—these are usually: address of the Internet service, date of publishing, lifetime of a Cookie, unique number and additional information corresponding to the intended use of a particular file. The terms regulating collection of Cookies by Comicspring are compliant with the Regulation concerning the respect for private life and the protection of personal data in electronic communications 2002/58/EC (e-Privacy Regulation). The collection shall be carried out only for the purpose of and in connection with the performance of the Agreement by Comicspring.

4.2. Comicspring shall use two types of Cookies: session cookies, which are permanently deleted upon the closing of Service Provider the session of the User’s browser, and permanent cookies, which remain on the User’s device after closing the session until they are deleted, whereby in the case of the latter type of files collection and storage of the relevant type of cookies may take place upon consent of the User through selection of relevant settings in the Internet browser.

4.3. It is not possible to identify the User on the basis of Cookie files, whether session or permanent. The Cookie mechanism prevents collection of any personal data by introducing the procedure of anonymisation, pseudonymisation and separation, aggregation etc. of data and other solutions effectively protecting User’s privacy.

4.4. The Cookies used on the website are safe for User’s device, in particular they prevent viruses or other software from breaking into to the device.

4.5. The User may disable storing Cookies on his/her device in accordance with the instructions of the browser producer, but this may disable entire services or parts of them.

4.6. Comicspring shall use own Cookies for the following purposes: authenticating the User and preserving User’s session; adjusting the content of sites to User’s preferences, such as: recognizing User’s device, remembering settings set up by the User; Cookies ensuring security of data; analyses and researches of views; advertisement services.

4.7. Subject to prior consent of the User if he/she selects certain settings in the Internet browser settings used, Comicspring shall use third-party Cookies for the following purposes: preparing statistics (anonymous) for the purposes of optimizing functionality of the website by means of analytic tools such as Google Analytics; using interactive functions by means of social networks, in this facebook.com.

4.8. The User may individually change the Cookies settings at any time, stating the conditions of their storage in the scope of privacy settings, thereby giving his/her consent to change the protection level in this scope, through the Internet browser settings or configuration of the service. The User may also individually delete Cookies stored on his/her device at any time in accordance with the instructions of the browser producer, provided that he/she gave his/her consent to their earlier storage.

4.9. Detailed information concerning Cookies support is available in the browser settings.

5. PERSONAL DATA OF PERSONS BELOW THE AGE OF 13

5.1. Comicspring shall not process personal data of persons below the age of 13, unless it has obtained the consent of a legal custodian of such person. Persons below the age of 13 may only use the services provided by Comicspring within the Website and whose personal data will be processed in connection with this shall obtain prior consent of the legal custodian whose identity shall be verified by Comicspring before proceeding to the processing.