Effective Date: January 29, 2015


ComiXology User Privacy Policy

For Web Services and Applications

(For comixology.eu and Related comiXology Services)


At comiXology, we respect your privacy.  We endeavor to make our policies for the collection and use of information relating to you and others who use our services understandable, fair, and consistent with applicable privacy and data protection laws. This Privacy Policy (this “Policy”) describes the personal data we collect, how we use that data, the purposes for which we share that data with others, and how you can contact us to ask any questions or express any concerns you may have about our privacy practices or data that you have provided.  


This Policy applies to data collected by our applications for mobile and tablet devices, laptops, and desktops (collectively, the “App”) and the website www.comixology.eu (the “Site”).  We may refer to the App, the Site, and related comiXology services collectively as our “Service.” We refer to the comic books and other content offered through our service as “Content.” Words such as “purchase” or “sale” (and similar terms, including all tenses), as applied to Content (including any Content the Company makes available for free), refer to the grant to you of a limited license as described in the applicable end user license agreement or terms of use. This Policy does not cover the collection and use of your personal data by our business partners.


The company that does business as comiXology and provides the Service is Iconology, Inc. (the “Company”), 512 Seventh Avenue, 12th FL, New York, NY 10018 (USA).  You can contact us by email at support@comixology.com. We may also refer to the Company by words such as “we,” “us,” or “our.”


By using the Service, you agree to the terms of this Policy and you consent to the processing of your personal data as described in this Policy, including in particular, the transfer of your personal data to third parties, the use of cookies and similar technologies, and the transfer of your personal data to the U.S.


1. Personal Data We Collect and How We Use It


We may collect personal data when you use our Service. By personal data we mean any information relating to an identified or identifiable natural person. We may use personal data to operate and optimize our Service and comply with legal obligations and for other purposes as described below.


The data we collect and process is either input by you or generated by your use of our Service and collected automatically. We describe these two types of information below and explain how, alone or in combination with other data we collect, we use them.


1.1 Information You Input

You may input information to make use of certain features of our Service.  For example, when you create an account with us you will enter information about yourself such as username, email address, birthdate, and other relevant information we request, and when you use the search features on our Service you enter the terms you wish to search for. You enter your payment method information to purchase Content through your account with us. 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.


When you purchase Content offered in the App using your account with a third party app store we do not collect the payment method information that you use for such purchases, and we are not responsible for the policies and practices of such app stores.


We use your account with us to allow Content that you have purchased while logged in on one device to be accessible (synchronize) on all devices through which you access our Service while logged into your account. Our specialized applications, which are limited to certain types of Content, may only be used to access and read Content within the scope of the Content they offer (for example, applications that offer content only from a specific publisher can only be used to access Content from that publisher). Records of all Content synchronized to your account with us may be used and shared as described in this Policy, including Content initially purchased through a service of ours with a separate privacy policy (for example, Content initially purchased through one of our mobile applications and then synchronized to your account).


We may use your search terms to recommend to you Content that we think might interest you.  With your consent, we may use your email address to let you know about products, services, events, or issues relating to the world of comic books and other content that might interest you.  You may opt out of receiving marketing emails through a link in such emails or by notifying us at support@comixology.com.  Whether or not you opt out of such emails, we may use your email address to provide information to you regarding your purchases, including any enhanced features that may be made available, changes to our terms of use or policies, service or operational matters, or other matters as permitted by applicable law.


We may use your birthdate to determine if you are qualified to create an account with us or purchase certain Content or to understand the age distribution of our customers. If you receive our marketing emails, we may send you an annual “happy birthday” message that may also contain product offers.


1.2 Personal Data We Collect Automatically


Your use of our Service generates information that the Company collects automatically. This section summarizes the important types of information that we may collect.  


Hardware, Software, and Network Data

We may collect information about the type and version of the device you use to access our Service, 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 (but not your mobile phone number). In the case of the App, this information may include an identifier generated by us or by the operating system of your device to enable us to identify the App that you have downloaded.


This information will enable us to provide to your device Content properly configured for that device, to keep a record of the Content that you purchase, and to analyze activity on our Service.  If you choose to create an account with us, that record will enable you to synchronize Content as described above.


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.


Content Selection


We may collect information about the Content that you purchase, place in your cart without purchasing, or search for or browse.  We may use that information to recommend to you Content that we believe might interest you.


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 our Service or on other Company or third party services. This may include information about whether you accessed our Service, what pages or views you accessed, how long you stayed on each page or view, any links you clicked on while on the site, the website you came from, what Content you browsed, placed in your cart, or purchased, as well as the hardware, software, and network data discussed in the preceding section. Such tracking technologies may include cookies (small pieces of information that a website places on a computer or mobile device used to access the Internet that can be used to recognize a return visitor and collect and store information about your prior activity on the Site), pixel tags (also referred to as web beacons, which are pieces of data embedded in an image on a website or email that allow for tracking of your activity on a website or your actions with regard to an email, such as whether you opened the email or accessed a link within the email), and anonymous identifiers (text strings that function like cookies, but used on mobile devices or other platforms that do not accommodate cookies).


We, or third parties with our permission, may use Tracking Technologies in the following ways:

        * To manage our business and improve our Service based on factors such as how many users visit or use our Service, what pages and views are accessed, whether visitors are new or repeat visitors, which features and Content of our Service most interest our visitors, and how our Service performs from a technical point of view (such as the speed with which content loads and the incidence of technical problems).


        * To provide personalized recommendations, Content, advertising, marketing emails, and guidance on Service features based on your activity on our Service, such as prior purchases, abandoned shopping cart selections, and browsing activities.


        * To remember actions you took to avoid asking you to repeat them during a session or to provide features such as enabling you to resume reading at the last page you accessed, synchronized across devices.


        * To enable us or third party sites or services or advertising companies to collect and store information regarding your activity on the App, the Site, our other services, or third party services to provide you with personalized recommendations or content or to provide you or broader advertising audiences with advertisements tailored to your or such audiences’ inferred interests, or to measure the effectiveness of marketing campaigns.  The third party advertisers may serve advertisements for us or for other companies on the App, the Site, our other services, or on third party services.


        * To measure and analyze activity on the App, the Site, our other services, and third party services. In addition to the uses outlined above, we or any provider of such measurement and analytical services may provide non-personally identifiable data to third parties.


Generally, Internet browsers contain controls for managing cookies.  Those controls may enable you to delete cookies or to accept or reject certain categories of cookies. You may be able to manage other (non-cookie) tracking technologies through the websites of the firms that provide such technologies or through the operating system of your mobile device.  You should consult the “Help” section of your browser or the website of your hardware, software, or operating system providers for further information. You can also learn more about cookies by visiting http://www.allaboutcookies.org/, which includes additional useful information on cookies and how to block cookies using different types of browsers. If you reject or delete cookies the related features and functions of our Site may be unavailable to you and the performance of our Site as experienced by you may be impaired.


For more information about cookies, see our Cookie Policy.


Remarketing on Our Site


We may use Google remarketing services, which allow third parties, including Google, to serve advertisements to you on our behalf based on your activity on our Site.  This involves placing on our Site pages a small piece of code provided by Google.  This code enables third parties, including Google, to place a cookie on your computer that tells them about your visit to our Site and allows them to recognize you and display relevant advertisements when you visit other websites within the Google Display Network. We may also use similar remarketing services from other companies.


Customize Google Analytics


You can learn how to customize or opt-out of receiving personalized online advertisements from Google by follow 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/


2. Your Rights and Choices


You have the right to access the personal data we maintain about you or to request that your personal data be rectified, or updated. You may also object to the processing of your personal data by us for legitimate reasons. If you decide you no longer want us to process your personal data, you should uninstall the App, and, if you have an account, at your request we will delete your account and make your user profile anonymous in the database. You will no longer be able to use our Service if you do this. You may exercise the rights mentioned in this section 2 by using the contact details provided below under “How to Contact Us.”


If you receive any marketing emails from us, you may ask us not to send you any such emails by clicking on the “unsubscribe” link included in the email you received, or by emailing your request to support@comixology.com.  All such requests will be honored.


3.  Data We Transfer to Third Parties


We may transfer your personal data to the following, or under any of the following circumstances:


        * Our corporate affiliates such as a corporate subsidiary.


        * Our current and 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 our Service or their services you have requested a product or service that requires us to transfer the data, or (c) if you use your account credentials to create an account with or log into any other service, including the digital stores operated under the brands of such partners and for which we provide technology or management services, your account information, including email address, will be transferred to such other services and will be subject to applicable law and the privacy policies and terms of service of such services.


        * Third parties we have retained to perform services on our behalf, such as Content hosting and delivery, data analytics, marketing and advertising, and payment services. Such service providers are contractually required to ensure the security and confidentiality of the data. We do not authorize service providers to use or disclose the data except as necessary to perform services on our behalf or to comply with legal requirements.


        * In connection with a business transaction involving transfer of our Company or a business of ours, information relating to customers typically would be included in the assets transferred.


        * If you consent.


        * For 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.


4. International Transfers


We are based in the United States (“U.S.”).  Although you may access our Service from a location outside of the U.S., any data collected in connection with our Service may be transferred to, processed, and stored within the U.S.  The U.S. may not have the same data protection framework as the country in which you may be using our Service. When we transfer your data to the U.S., we will treat you personal data in accordance with the requirements of the Safe Harbor Principles.


5. Data Retention and Security


We retain personal data for as long as necessary to provide our Service and to fulfill any other purposes for which the data was initially collected. We maintain appropriate administrative, technical and physical safeguards to protect personal data against loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We use Secure Sockets Layer encryption for the transmission of account registration data, and in other instances where appropriate. We will never ask you for your password in any unsolicited communication (including by telephone or e-mail). If you believe your username or password has been compromised, please contact us at support@comixology.com. You should understand that no feasible system of data security is invulnerable.


6. 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, the related data processing practices, or any other aspects of those sites and services.


7. Changes to this Policy


We may change this Policy at any time and without prior notice to you.  If the changes are material, we will notify you by posting or displaying a notice on this page, by email, on an updated App available for free download, or by any other method we choose in our discretion. Changes are effective when disclosed, or at such later date as may be stated in the revised Policy. Your use of the Service after a change is effective will be governed by the 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 to 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 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 Policy.


8. How to Contact Us


If you have any questions or concerns about our privacy practices or data that you have provided, please contact our subsidiary by writing to ComiXology Europe SAS,  42 avenue Montaigne, 75008 Paris (France), or the Company by email at support@comixology.com; by writing to Iconology, Inc. (comiXology), 512 Seventh Avenue, 12th Floor, New York, NY 10018 (USA); or by phone at 1 (646) 412-7917 and reference subject “Privacy” in any written communications. 


Inquiries relating to transactions with the app store from which you downloaded our App, including billing questions regarding the purchase of our Content, should be directed to the app store through which you made the purchase.