Comicle Privacy Policy

Introduction

Amutus Corporation (“we,“ “us,” or “our”) provides a mobile application named Comicle (the “App”) which enables you to access e-books and other digital contents (collectively, the “Digital Content”). We comply with applicable data privacy laws and properly handle your personal information collected with regard to your use of the App and any related services (collectively, the “Services”) pursuant to this Comicle Privacy Policy (this “Privacy Policy”).

Personal Information We Collect

We collect the following categories of your personal information.

Account information
We collect your personal information such as that listed below at the time when you create or update an account:
- Email address;
- Password, which will immediately be hashed;
- Settings and preferences of the Services; and
- User IDs which we assign to you.
Information with regard to your use of the Services
We collect your personal information such as that listed below in relation to your use of our Services, including reading, searching or bookmarking Digital Content, or purchasing or using coins:
- Search history of Digital Content;
- Titles of Contents you checked and bookmarks you made;
- Reading progress status of Digital Content;
- Current balance of coins, and purchase and use history of coins; and
- Inferences regarding your preferences drawn from the above information and our recommendations based thereon.
Personal information automatically collected from your device
At the time when you are using the App, we collect your personal information such as that listed below from the device that you are using:
- Technical information such as types and versions of OS or language settings;
- Internet Protocol address and approximate geolocation information based thereon;
- Online identifiers such as advertising ID;
- Log information including access times, and pages and content viewed; and
- Your interactions with advertisements in the App.
Others
We collect other personal information that you voluntarily provide to us such as that listed below:
- Content of inquiries you make; and
- Content of your responses to questionnaire surveys.

<Social Plug-Ins>

All of your personal information is generally collected from you or your device; however, if you create an account or login to the Services by using a social plug-in service from an external service provider, we will collect your email address and other identifiers from the service providers based on your specific consent.

<Payment Information>

When you make any payments in the App, you will be required to do so via the payment services provided by external payment service providers. Your credit card number and other payment information will be directly transmitted to such payment service providers, and we will not collect such information.

<Sensitive Personal Information>

We do not collect, use or disclose any sensitive personal information, such as information revealing your racial or ethnic origin, religious or philosophical beliefs, precise geolocation, or credit card number in combination with password, in relation to the Services.

<Personal Information of Minors>

As the Services are only available to people seventeen years of age or older, we do not knowingly collect personal information from minors under seventeen years of age in relation to the Services. If we discover that we have collected personal information from minors under seventeen years of age, we will take steps to delete such information as soon as possible. If you become aware that a minor under seventeen years of age has provided us with personal information, please contact us immediately at the contact information set forth in “10. Contact Information” below.

Purposes of the Collection and Processing of Personal Information

We will collect and process your personal information for the following purposes:

To provide you with the Services, such as:
- enabling you to login to the Services, read or bookmark Digital Content, review your history of reading, purchase or use coins, or post your reviews;
- customizing the Digital Content to be displayed pursuant to our inferences regarding your preferences;
- managing your account information and providing notices on necessary matters;
- answering your inquiries;
- charging fees, if applicable; and
- ensuring security
To improve the quality of the Services and customer satisfaction, such as:
- Carrying out questionnaire surveys; and
- Conducting user experience research such as A/B testing
To distribute advertisements, such as:
- Distributing targeted advertisements tailored to you both inside and outside the App, based on your attributes and activities in the App; and
- Distributing rewarded advertisements such as offerwall ads or rewarded video ads in the App
To investigate and analyze your personal data and generate statistical information for the purpose of our marketing analysis or developing or improving our products or services or for the purpose of providing such statistical information to third parties such as providers of Digital Content.

In principle, we will collect and process your personal information within the scope of the purposes set forth above, and when we use your personal information outside the scope of those purposes, we will obtain your prior consent unless otherwise permitted by applicable law.

Disclosure and Sale/Sharing of Your Personal Information

We may and have disclosed your personal information to our service providers who process your personal information on our behalf for the purposes described in “3. Purposes of the Collection and Processing of Personal Information” above.

In addition, as shown in the table below, we may and have sold your personal information for valuable consideration and shared your personal information for cross-context behavioral advertising (i.e., behavioral advertising based on personal information collected across multiple websites, applications, etc.). However, we do not knowingly sell or share personal information of data subjects under 16 years of age as the Services are provided only for users who are 17 years or older.

<Sale/Sharing to Third Parties>

Purpose of Sale/Sharing	Categories of Third Parties	Categories of Personal Information
To distribute targeted advertisements in the Services	Platforms distributing targeted advertisements in the Services	The fact that you use the App Transactional or “event” data related to your interaction with the App, such as information about the actions taken in the App like purchases or application installations Your interactions with advertisements in the App Technical information such as types and versions of OS or language settings Internet Protocol address and approximate geolocation information based thereon Online identifiers such as advertising ID Advertising and tracking preferences and restrictions
To distribute rewarded advertisements such as offerwall ads or rewarded video ads	Platforms distributing rewarded advertisements in the Services

International Transfer of Personal information

In principle, your personal information is stored within the U.S. or Japan. Please note, however, that, to the extent necessary for the purposes specified in “3. Purposes of the Collection and Processing of Personal Information” above, your personal information may be transferred to and stored in countries/regions outside the U.S. and Japan, and that such country/region may not have the same level of data privacy as that provided within the U.S. and Japan. In the course of the international transfer of your personal information, we will take adequate measures to protect your personal information and ensure that related collection and processing of your personal information are in accordance with applicable laws.

Data Retention

To delete your account, please access “Settings” > “Account” > “Delete Account.” Please note that we may retain your personal information even after you delete your account with the App as needed, including to comply with legal obligations and fulfill the purposes specified in “3. Purposes of the Collection and Processing of Personal Information” above.

Security

We implement reasonable security procedures and practices appropriate to the nature of the personal information in order to protect the personal information from unauthorized or illegal access, destruction, use, modification or disclosure. The security procedures and practices we have implemented include the following:

Regulations Regarding Handling of Personal Information
Regulations have been established regarding the acquisition, use, storage, provision, deletion, and disposal of personal information, including handling methods, responsible persons and persons in charge, and their duties.
Organizational Safety Management Measures
- In addition to appointing a person responsible for handling personal information, we have established a system to clarify the employees who handle personal information and the scope of personal information handled by them, and to report to the person responsible any facts or signs of violation of laws and regulations or handling rules when they are discovered.
- We conduct regular self-inspections of the status of personal information handling.
- We have obtained Privacy Mark certification from the Japan Institute for Promotion of Digital Economy and Community (JIPDC), and at every renewal of the certification we undergo the inspection conducted by the Japan Users Association of Information Systems (JUAS) and take necessary measures to deal with any issues detected in such inspection.
Human-Related Safety Management Measures for People
The confidentiality of personal information is described in our employment regulations. We provide regular education and training to employees on personal data privacy laws and related restrictions, and on our internal rules regarding the handling of personal data, including our employment regulations.
Technical Safety Management Measures
- Access control is implemented for equipment, electronic media, and external services that handle personal information to prohibit access by persons other than those in charge, and access logs are maintained in order to prevent any unnecessary access to personal information.
- Security measures are implemented for equipment, electronic media and external services that handle personal information in order to protect them from unauthorized access and unauthorized software.

Your Rights

You may have certain rights regarding your personal information under applicable data privacy laws, which may include the following rights. These rights should be exercised based on and in accordance with applicable data privacy laws.

Right to Know, Correct, Delete and Others
1. The right to know what personal information we have collected about you, including:
  - The categories of personal information;
  - The categories of sources from which the personal information is collected;
  - The business or commercial purpose for collecting, selling, and sharing personal information;
  - The categories of third parties to whom we disclose personal information; and
  - The specific pieces of your personal information
2. The right to delete personal information that we have collected from you
3. The right to the correction of inaccurate personal information that we maintain about you
4. The right not to receive discriminatory treatment by us for the exercise of privacy rights conferred by applicable data privacy law
5. The right to obtain a copy of your personal information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allow you to transmit the information to third parties
6. The right to opt out of the processing of your personal information for purposes of profiling in furtherance of a decision that produces a legal or similarly significant effect concerning you
7. The right to appeal our decision to decline to take action regarding your request; if you are a Texas resident and we denied your appeal, you can submit a complaint to the Texas Attorney General via the Texas Complaint Portal
If you wish to exercise any of the rights under applicable data privacy laws, please contact us using the contact information set forth in “10. Contact Information” below.
As required under applicable law, we will take needed steps to verify your identity before responding to your request. We may require you to provide information, depending on the sensitivity of the information you are requesting and the type of request you are making. If you use an agent to submit a request, we will require the agent to provide us with proof that you gave the agent signed permission to submit the request.
Right to Opt-Out of Sale/Sharing

We may sell your personal information for valuable consideration and share your personal information for cross-context behavioral advertising, as shown in “4. Disclosure and Sale/Sharing of Your Personal Information.”

Under applicable laws, you may have the right to opt-out of our sale and sharing of your personal information. If you would like us to stop selling and sharing your personal information, you can submit your opt-out request by using the toggle button in the “Do Not Sell or Share My Personal Information” page which is accessible from the setting menu in the App. You can also submit the request by sending an email with your User ID to privacy@amutus.co.jp. To find your User ID, please access “More” > “Help” > “Contact us” in the App.

Modification to Privacy Policy

We will review this Privacy Policy as necessary and make continuous improvements from time to time in order to reflect your feedback or to comply with changes in our legal and/or regulatory obligations. When we make important changes to this Privacy Policy, we will notify you of such changes in the App, if required under applicable law, we will obtain your prior consent before implementing such changes.

Contact Information

If you have any questions, comments or requests regarding this Privacy Policy, please contact us at:

Amutus Corporation
Personal Information Protection Desk
Mail: Midtown East 10F, 9-7-2 Akasaka, Minato-ku, Tokyo 107-0052, Japan
Email: privacy@amutus.co.jp
You can also contact us via the "Contact Us" form on the App.

California Privacy Rights

This section applies only if you are a California resident.

Notice at Collection
Under the California Consumer Privacy Act (CCPA), you are entitled to certain notice of our practices regarding your personal information. The following is intended to provide you with such notice.
We may collect your personal information and use it for specific purposes. The categories of personal information that we collect are your identifiers, commercial information, internet or other electronic network activity information, geolocation data, and inferences regarding your preferences drawn from your information, as described in “2. Personal Information We Collect” above. For a list of the purposes for which we use such personal information, please see “3. Purposes of the Collection and Processing of Personal Information” above.
We may and have sold your personal information for valuable consideration and shared your personal information for cross-context behavioral advertising. For further information, please see “Right to Opt-Out of Sale/Sharing” below. For the criteria used to determine the period for which we retain your personal information, please see “6. Data Retention”.
Right to Know, Correct and Delete
Under the CCPA, you have the right to know, correct and delete your personal information as described in “8. Your Rights,” with certain exceptions.
Right to Opt-Out of Sale/Sharing
With regard to your right to opt-out of sale or sharing of your personal information under the CCPA, please see “8. Your Rights”.
Do Not Track signals
Some online services have a “Do Not Track” feature that allows you to send a signal to the online service you use indicating that you do not wish to be tracked. Please note that our Services do not currently support “Do Not Track” signals.
Collection of Personally Identifiable Information by Third Parties
Third parties may not collect “personally identifiable information” about your online activities over time and across different websites when you use the App. Some service providers, however, may collect your personal data on our behalf when you use the App.