Privacy Policy

• 1.
  What information do we collect?

  1. 1.1
     Personal information you disclose to us. We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

  1. 1.2
     Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

     1. (a)
        email addresses

     1. (b)
        usernames

     1. (c)
        passwords

     1. (d)
        contact preferences

     1. (e)
        debit/credit card numbers

     1. (f)
        billing addresses

     1. (g)
        contact or authentication data

     1. (h)
        phone numbers

     1. (i)
        names

     1. (j)
        mailing addresses

  1. 1.3
     Sensitive Information. We do not process sensitive information.

  1. 1.4
     Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Stripe. You may find their privacy policy link(s) here.

  1. 1.5
     Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

  1. 1.6
     All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

  1. 1.7
     Information automatically collected. We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

  1. 1.8
     Like many businesses, we may also collect information through cookies and similar technologies. You can find out more about this in our Cookie Policy.

  1. 1.9
     The information we collect may include:

     1. (a)
        Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

     1. (b)
        Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

     1. (c)
        Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

• 2.
  How do we process your information?

  1. 2.1
     We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

     1. (a)
        to facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order;

     1. (b)
        to deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service;

     1. (c)
        to respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service;

     1. (d)
        to send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information;

     1. (e)
        to fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services;

     1. (f)
        to enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user;

     1. (g)
        to request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services;

     1. (h)
        to send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below);

     1. (i)
        to deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more. For more information see our Cookie Policy;

     1. (j)
        to protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention;

     1. (k)
        to identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them;

     1. (l)
        to determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you; and

     1. (m)
        to save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

• 3.
  What legal bases do we rely on to process your information?

  1. 3.1
     For EU or UK users. The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

     1. (a)
        Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.

     1. (b)
        Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

     1. (c)
        Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

        1. (i)
           send users information about special offers and discounts on our products and services;

        1. (ii)
           develop and display personalized and relevant advertising content for our users;

        1. (iii)
           analyze how our services are used so we can improve them to engage and retain users;

        1. (iv)
           support our marketing activities;

        1. (v)
           diagnose problems and/or prevent fraudulent activities; and

        1. (vi)
           understand how our users use our products and services so we can improve user experience.

     1. (d)
        Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

     1. (e)
        Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

  1. 3.2
     For Canadian uses. We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

     1. (a)
        if collection is clearly in the interests of an individual and consent cannot be obtained in a timely way;

     1. (b)
        for investigations and fraud detection and prevention;

     1. (c)
        for business transactions provided certain conditions are met;

     1. (d)
        if it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim;

     1. (e)
        for identifying injured, ill, or deceased persons and communicating with next of kin;

     1. (f)
        if we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse;

     1. (g)
        if it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;

     1. (h)
        if disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records;

     1. (i)
        if it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced;

     1. (j)
        if the collection is solely for journalistic, artistic, or literary purposes; and

     1. (k)
        if the information is publicly available and is specified by the regulations.

• 4.
  When and with whom do we share your personal information?

  1. 4.1
     Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:

     1. (a)
        Ad Networks;

     1. (b)
        Data Analytics Services;

     1. (c)
        Payment Processors;

     1. (d)
        Sales & Marketing Tools;

     1. (e)
        Social Networks;

     1. (f)
        User Account Registration & Authentication Services;

     1. (g)
        Website Hosting Service Providers;

     1. (h)
        Testing Tools;

     1. (i)
        Retargeting Platforms;

     1. (j)
        Performance Monitoring Tools;

     1. (k)
        Order Fulfillment Service Providers;

     1. (l)
        Data Storage Service Providers;

     1. (m)
        Communication & Collaboration Tools;

     1. (n)
        Affiliate Marketing Programs; and

     1. (o)
        Cloud Computing Services.

  1. 4.2
     We also may need to share your personal information in the following situations:

     1. (a)
        Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

     1. (b)
        Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

     1. (c)
        Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

     1. (d)
        Other Users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

• 5.
  What is our stance on third-party websites?

  1. 5.1
     The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications.

  1. 5.2
     Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications.

  1. 5.3
     The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties.

  1. 5.4
     Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

• 6.
  Do we use cookies and other tracking technologies?

  1. 6.1
     We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

• 7.
  How do we handle your social logins?

  1. 7.1
     Our Services may offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

  1. 7.2
     We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy policy to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

• 8.
  Is your information transferred internationally?

  1. 8.1
     Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information, in the United States, and other countries.

  1. 8.2
     If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.

  1. 8.3
     European Commission’s Standard Contractual Clauses: We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Data Processing Agreements that include Standard Contractual Clauses are available here. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

• 9.
  How long do we keep your information?

  1. 9.1
     We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

  1. 9.2
     No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us.

  1. 9.3
     When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

• 10.
  How do we keep your information safe?

  1. 10.1
     We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process.

  1. 10.2
     However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

  1. 10.3
     Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

• 11.
  What are your privacy rights?

  1. 11.1
     In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section below.

  1. 11.2
     We will consider and act upon any request in accordance with applicable data protection laws.

  1. 11.3
     If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here.

  1. 11.4
     If you are located in Switzerland, the contact details for the data protection authorities are available here.

  1. 11.5
     Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section below or updating your preferences. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

  1. 11.6
     Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

  1. 11.7
     Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account.

  1. 11.8
     Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

  1. 11.9
     Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services visit here. For further information, please see our Cookie Policy.

  1. 11.10
     If you have questions or comments about your privacy rights, you may email us at hello@namicomi.com.

• 12.
  Controls for do-not-track features

  1. 12.1
     Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

• 13.
  Do California residents have specific privacy rights?

  1. 13.1
     Yes, see our California Privacy Policy.

• 14.
  Do we make updates to this policy?

  1. 14.1
     We may update this privacy policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible.

  1. 14.2
     If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.

  1. 14.3
     We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

• 15.
  How can you contact us about this policy?

  1. 15.1
     If you have questions or comments about this policy, you may email us at corporate@namicomi.com or by post to: NamiComi, Inc., 228 Park Ave S, New York, NY 10003, United States.

• 16.
  How can you review, update, or delete the data we collect from you?

  1. 16.1
     Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it.

  1. 16.2
     To review, update, or delete your personal information, please visit your settings page.

The English version of this document is the definitive version. Translations into other languages are provided for information only.

Last updated: 10th February 2023