GRAPHITE PRIVACY POLICY

Last Updated: October 22, 2018

We at Graphite respect your privacy.

This Privacy Policy applies to information collected by Graphite on the Graphite services “Graphite Services”, which includes Graphite websites, Graphite mobile applications, Graphite emails and newsletters, and Graphite’s accounts on third-party social networking sites. This Privacy Policy describes the information we collect, how we use that information, the purposes for which we share such information with others, and how you can contact us with questions or comments you may have about this Privacy Policy.

We may develop new or additional services or features from time to time. These new or additional services or features will be subject to this Privacy Policy unless the introduction of these services or features results in a change to the way in which we collect or process your personal data. In the event there is a change to the way we collect or process your personal data, we will provide you with the applicable information and additional terms and policies in accordance with Section 9, Modifications to this Privacy Policy.

This Privacy Policy does not cover the collection and use of your personal data by our business partners. Please consult their privacy policies and terms of use for information about their practices. Although the Graphite Services may include third party links, such as links to third party e-commerce stores or content partner sites, this Privacy Policy does not cover the policies or actions of these third-party sites. This Privacy Policy does not cover any information that may relate to Graphite outside of the Graphite Services.

The terms governing your use of the Graphite Services are not covered in this Privacy Policy.  Graphite’s Terms and Conditions which govern your use of the Graphite Services can be found at www.graphitecomics.com/terms.

CONTACT INFORMATION

Graphite Comics is fully owned and operated by Graphite LLC, with a location at 1434 6th Street Suite 8, Santa Monica CA90401. You can contact us at agency@graphitecomics.com.

  1. Information Collection

1.1 Information You Provide

Registration Information. When you create an account with us, we ask for your username, email address, and other relevant information.

We may use your email address to send you marketing emails which may include information on Graphite Services, events, services or other content. Our marketing emails tell you how to opt-out of receiving further marketing emails.  You may also contact us at agency@graphitecomics.com to opt out. If you opt out, we may still send you non-marketing emails, such as emails about your account and our business dealings with you and other matters as permitted by applicable law.

Payment Information. When you add a credit card or payment method to your account or create a subscription account with us, we collect your payment information and billing address. Such payment method information (including account numbers, expiration dates, and security codes) is transferred to a third-party provider of payment services and is not retained by us.

Communications. If you contact us directly, we may receive additional information you provide, such as your name, email address, phone number, the contents of a message or attachments that you may send to us.

Use of Features. We may receive information when you use certain features of the Graphite Services. For example, if you use the search features on Graphite Services we may collect the search terms you entered.  We may use the terms you entered in the search features to personalize recommendations of content available on the Graphite Services.

Information you Provide About Others. We may also collect the personal information of other people, for example, if you provide email addresses of friends for referrals.

1.2 Information We Collect as You Use the Graphite Services

Hardware, Software, and Network Data. We may collect information about the type and version of the device you use to access the Graphite Services, operating system, IP address assigned to the device by the third party providing Internet access to the device, unique device identifiers, and mobile network information, including mobile phone number. In the case of our mobile application, this information may include an identifier generated by us or by the operating system of your device to enable us to identify the mobile application that you have downloaded.

This information will enable us to provide to your device content that is properly configured for that device, to keep a record of the content that you download, and to analyze activity on the Graphite Services.

In addition to the uses noted above, we may use IP addresses to detect and mitigate fraud or to determine what State, postal code and/or Country the device is in. We may use that data to comply with various legal obligations, such as geographic restrictions on the distribution of certain content and payment of taxes, to display geographically appropriate content, policies, notices, and advertisements, and to better understand the geographic distribution of our customers.

Tracking Technologies, Including Cookies. We use, and allow third parties to use, various technologies (“Tracking Technologies”) that enable tracking and collection of information about your activity on the Graphite Services or on other Graphite or third party services. This may include information about whether you accessed the Graphite Services, what content, pages, or views you accessed, how long you stayed on each page or view, any links you clicked on while on the Graphite Service, the website or other property you came from, what content you browsed, downloaded, as well as the hardware, software, and network data discussed in the Hardware, Software, and Network Data section above. Such Tracking Technologies may include cookies , pixel tags, anonymous identifiers, or similar technologies.

You may be able to manage cookies and other tracking technologies via your internet browser management controls. Please see the applicable Help section of your internet browser for more information on what is available to you.  If you reject or delete cookies the related features and functions of the applicable Graphite Services may be unavailable to you and the performance as experienced by you may be impaired.

Your Activity on the Graphite Services.  We receive information about your interactions with the Graphite Services, such as when you access the Graphite Services, your search history, search results, content you access (including open issues, your favorited and subscribed content, and usage statistics such as what content you access, the time you access them, and how long you spend viewing them), interactions with content and advertisements, and settings and preferences.

  1. Information Usage.

Information collected by Graphite is or may be used by Graphite and others on Graphite’s behalf for the following purposes:

Support and Maintenance: to provide and maintain the Graphite Services, and to process and fulfill your requests or subscriptions;

Improvement of Graphite Services: to understand and analyze our user base and how you use the Graphite Services, and to improve and enhance the Graphite Services, and to develop new products, services, features and functionality;

Personalization: to personalize your experience, including suggesting and offering you relevant content and recommendations;

Advertising: to show you personalized advertising on the Graphite Services and to understand the effectiveness of such advertising;

Marketing and Promotions: for marketing purposes, including sending you emails and text messages about products, events, promotions and offers from Graphite or its partners or advertisers, and understanding the effectiveness of our marketing;

Analytics and Performance: to measure performance and analyze key metrics relevant to our business;

Service Communication and Customer Care: to communicate with you, including sending you service information such as confirmations, invoices, notices, updates, security alerts, user surveys, and support and administrative messages; and to respond to your comments and questions and provide customer service;

Protect Graphite, our Users and Others: to enforce our terms and conditions or protect our business, partners or users; and

Security and Fraud Prevention: to protect, investigate, and deter against fraudulent, unauthorized, infringing or illegal activity.

  1. Information Sharing

3.1 Your Sharing

You can share reviews, feedback, comments, and content on Graphite Services, and Graphite forums, message boards, and accounts on third-party social networking sites. Information posted in these venues may be available to the public. You can also share with Graphite personal information of other people as described in Information You Provide (e.g., for referrals). We rely on you to obtain the permission of those other people to allow us to collect their personal information. Please be mindful of your own privacy needs and those of others as you choose what to share and make public. We cannot control the privacy or security of information you choose to make public.

3.2 Graphite’s Sharing

We may share your information with the following, or under any of the following circumstances:

Corporate Affiliates. We may share some or all of your information with our current or future “affiliates” (which means a parent company, any subsidiaries, joint ventures, or other companies under common control), in which case we will require our affiliates to honor this Privacy Policy.

Content Providers and Business Partners. Graphite shares information with third parties whose content is available through the Graphite Services. For example, Graphite may provide them with aggregated reporting on the performance of their content, such as the total number of page views. We may also share information with our current or prospective business partners, including publishers who provide content for any of our services, (a) who have a need to understand the nature and operation of our business, such as sales and usage trends or sales data underlying royalty calculations (information provided in this respect is not personally identifiable), (b) if through a Graphite Service or their services you have requested a product or service that requires us to transfer the information, or (c) if you opt-in to receiving information about our partners or affiliates.

Service Providers and Vendors. Graphite uses third parties (including contractors and service providers) to provide services for us and to help with our operations, which may require that they access and use your information. For example, Graphite may use a third party to communicate with you (via telephone, email, or letter) about our products or services, to send information to you, to process and collect payment via your credit card (if applicable), to provide customer support, to receive additional data about you, and to perform analytics and other work that we may need to outsource.

Analytics Providers. We use analytics services such as Google Analytics to collect and process certain analytics data on Graphite Services. These analytics services may also collect information regarding your use of third-party websites, apps, online services, and devices. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/ , and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout .

Advertising Partners. We may work with third-party advertising partners to show you advertisements that we think may interest you on Graphite Services and on third-party websites, apps, and devices. These advertising partners may set and access their own cookies, pixel tags and similar technologies on the Graphite Services and they may otherwise collect or have access to information about you which they may collect over time and across different online services and devices. If you do not wish to receive personalized advertisements, you can read about your choices below under Information Access and Choices.

Advertising Measurement Providers. We may work with third-party advertising measurement providers to help us and our advertisers understand the effectiveness of their ad campaigns. These measurement providers collect or receive information about your viewing of or interaction with advertisements. Graphite may also share your demographics data with advertising measurement providers.

We will not share information that personally identifies you directly with advertising measurement providers that use your information to provide services to their other clients. However, if these providers already have your identifiable information (e.g., if you have provided it to them or they have obtained it from a third party), then they may be able to associate that data with the information we provide to them. Measurement providers use your information to create statistics about what content and advertisements are being watched – for example, to help them and their clients understand the audience viewing the content or advertisements, and to measure the effectiveness of the advertisements.

Consent. Graphite may also share personally identifying information with your consent, for example, when you agree to our sharing of your personally identifying information with other third parties for their own marketing purposes, subject to their separate privacy policies.

Merger, Sale, or Other Asset Transfers. Graphite may also share your information with others in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture or disclosure of all or a portion of our business or assets to another company.

As Required by Law and Similar Disclosures.

Graphite may also share your information or the following reasons relating to legal matters or corporate responsibility based on our good faith assessment of the appropriate course under the circumstances: (a) as required by legal process or any law to which we are subject, (b) in response to a request by a court, law enforcement authority, or government agency or official that we believe would have the power to compel compliance if we refuse, (c) to protect our rights under our contracts, terms of service, and end user license agreements, and to otherwise protect our rights, (d) to protect the rights or welfare of others, including our employees and owners of copyright or other intellectual property in Content, (e) to prevent or mitigate physical harm to person or property or financial loss, (f) to assess or mitigate credit risk, and (g) to conduct any investigation relating to the foregoing.

Aggregated or De-Identified Information. We may also share aggregated or de-identified information (i.e., information that does not personally identify you directly), or statistical information about you, including demographics data with others for a variety of purposes, including for their own uses, for example, for improving their products and services for Graphite and others, and to make advertisements more relevant to your interests.

  1. Geography

We are based in the United States.  Any data collected in connection with the Graphite Services may be transferred to, processed, and stored within the United States or other countries in which we do business or our service providers transfer, process, or store data.

  1. Children Under 13

We do not knowingly collect personal information from children under 13.  Any parent or guardian who believes that a child may have provided personal information to us should contact us at agency@graphitecomics.com

  1. Data Security

Graphite uses industry-standard methods of securing its electronic databases of personal information. However, you should know that no company, including Graphite, can fully eliminate security risks associated with personal information. To help protect yourself, please use a strong password, do not use the same password to access your Graphite account that you use with other accounts or services, and protect your user names and passwords to help prevent others from accessing your accounts and services.

Personal information we collect may be retained for as long as needed to fulfill legitimate business purposes, including the purposes outlined in “Information Usage” or for a period of time specifically required or allowed by applicable regulations or laws.

  1. Links to Other Websites and Services

We may provide links to various third party websites and services.  Those sites and services are not under our control.  Those sites and services may have their own privacy policies, which we strongly suggest you review if you visit them or utilize them. We are not responsible for those third party privacy policies or the related data processing practices.

  1. Information Access and Choices.

We may use your email address to send you marketing emails which may include information on Graphite Services, events, services or other content. Our marketing emails tell you how to opt-out of receiving further marketing emails.  You may also contact us at agency@graphitecomics.com to opt out.  If you opt out, we may still send you non-marketing emails, such as emails about your account and our business dealings with you and other matters as permitted by applicable law.

You may be able to manage cookies and other tracking technologies via your internet browser management controls. Please see the applicable Help section of your internet browser for more information on what is available to you.  If you reject or delete cookies the related features and functions of the applicable Graphite Services may be unavailable to you and the performance as experienced by you may be impaired.

You may be able to opt-out of receiving personalized online advertisements from advertisers or advertising networks who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out sections on the websites of each of those organizations.  Links to those sites are here:

http://www.networkadvertising.org/choices/

http://www.aboutads.info/choices/

You can learn how to customize or opt-out of receiving personalized online advertisements from Google through this link: https://www.google.com/settings/ads. If you would like to opt-out of Google Analytics collecting data from your browser when you visit websites, you can download and install the Google Analytics Opt-out Browser Add-on here:  https://tools.google.com/dlpage/gaoptout/

  1. Modifications to this Privacy Policy

We may change this Policy at any time and without prior notice to you.  If the changes are material, we may notify you by posting or displaying a notice on this page, by email, on an updated mobile application available for free download, or by any other method we choose in our discretion. Changes are effective when the revised Policy is made available on a Graphite Service or through any other method we choose in our discretion, or at such later date as may be stated in the revised Privacy Policy. Your use of a Graphite Service after a change is effective will be governed by the Privacy Policy as changed. The Policy in effect at any time governs our use of all information in our possession at that time.  However, if we change the Policy in a way that materially reduces the protections afforded information collected prior to the change, we will not apply that change to that previously collected information without the consent of the affected customers. Please review this Privacy Policy from time to time while you are connected to the Internet so that you are aware of any changes.  We will indicate above the effective date of this Privacy Policy.