SINOPIA COMICS INC. DIGITAL PRIVACY POLICY

Effective: November 29, 2016.

This Privacy Policy describes the practices of Sinopia Comics Inc. (“Sinopia”, “we”, “us”, “our”) with respect to our collection, use, storage and disclosure of personal information (as defined herein), about you in connection with your use of our website located at www.sinopiacomics.com (the “Sinopia Website”), as well as any other related websites, software applications (“Apps”), toolbars, widgets, or other distribution channels, we may, from time to time, operate (collectively, “Sinopia Comics Digital”), and any other features, digital content viewer (including comics books, graphic novels, and other publications), blogs, reviews, comment pages, contact us pages, services, display services or applications offered, from time to time, by us (collectively referred to herein as the “Sinopia Services”).

This Privacy Policy applies to all of our owned and hosted websites, mobile applications and other online services. If you have any questions or feedback about this policy, please email us at: herohelp@sinopiacomics.com

1. COLLECTION OF PERSONAL INFORMATION

Personal Information” means information about an identifiable individual, including but not limited to, a first and last name, date of birth and an email address.

We collect Personal Information when you voluntarily provide it to us, or use the Sinopia Services. You are not obligated to provide your Personal Information, however we may not be able to provide you with access to the Sinopia Services, or portions thereof, without that Personal Information.

We collect several types of Personal Information from our customers, fans, and other visitors:

a.     Information provided by you: any Personal Information you input on our websites or mobile applications may be stored and used to provide you with content, improve our services and to contact you if necessary.

b.    Automatically-collected data: Your IP address, browser information, and referring website (if any) are all submitted automatically to our servers whenever you access our websites. We may log and analyze this information in order to monitor and improve our quality of service. We do not link your network address to any personal identifying information.

c.     Payment details: Sinopia provides a voluntary donation system to support content creators. When you submit payment information for a donation, including credit card and billing address details, that information is directly provided to our banking and payment-processing partners in order to process your donation.

d.     Emails: Use of Sinopia Services, including but not limited to, providing creator donations, requires the creation of an account and input of limited personal information. By creating an account and using the Sinopia Services you are agreeing to receive emails and electronic notifications from Sinopia with respect to your use of the Sinopia Services. We will send you email as is necessary to communicate with you about important events, or donation issues relating to your use of the Sinopia Services. These email messages may include services that allow us to monitor successful delivery of, and responses to, our email messages to you. You can change your notification preferences, but please note that while you are able to opt-out of receiving commercial emails and other electronic notifications, you cannot opt out of receiving important service messages or legal notices from Sinopia.

e.     Mobile device information: When using our mobile applications, we may collect information about your mobile device in order in order to protect against misuse. We may also collect aggregated information about the brand, model and capabilities of your mobile device(s) in order to direct future product upgrades and enhancements.

f.      Usage history: As you interact with our websites and applications, we will collect certain usage information, including pages viewed, products donated to, and content viewed.

2. YOUR CONSENT TO OUR COLLECTION OF PERSONAL INFORMATION

Third Party” refers to sponsors of Sinopia, business/advertising partners, and service vendors, who may use the Personal Information to create targeted marketing campaigns, promotions and contests. We do not control how these Third Parties use or disclose your Personal Information, once you have given Sinopia your express consent to disclose such Personal Information to them.

Except as described in this Privacy Policy, we will not disclose, share or sell your Personal Information without your express consent. In the event that we want to share your Personal Information with a Third Party, a notice (“Notice”) will be sent to you through email requesting permission to disclose your Personal Information to the Third Party. You will have the option to expressly consent, or to prohibit the disclosure of your Personal Information to the Third Party.

We will not seek your express consent to disclose, share or sell any aggregate, or non-identifying information, collected through the Sinopia Services. This information does not directly identify you.

3. USE OF PERSONAL INFORMATION

We will use information collected during your usage of our websites and applications to provide the Sinopia Services to you. We will also make information about usage history available to our customer service and business operation representatives, in order to ensure you receive the highest possible quality of service.

a.     Aggregate Information. We may also disclose, share or sell aggregated, anonymous information that includes or is based on information about you with Third Parties. This information is combined with the information of other users and does not directly identify you (“Aggregate Information”). We may not limit the Third Parties’ use of the Aggregate Information. Aggregate Information may also be used for our own internal analysis and operations to improve the performance, functionality and content of the Sinopia Services.

b.     Business Partners. We may provide your Personal Information, to companies that provide services to help us with our business activities (“Business Partners”), including processing any donations related to your use of the Sinopia Services, email list management, social media connectivity, data hosting providers, or customer service. These companies are authorized to use your Personal Information only as necessary to provide these services to us, and in a manner consistent with this Privacy Policy. Whenever possible, we will withhold any Personal Information from these Business Partners. Your access to the Sinopia Services may be limited if you opt-out of this disclosure.

c.     Internal Use. We may disclose Personal Information for our own internal analysis of data collected through your use of the Sinopia Services.

d.     Social Media. Personal Information collected through the Sinopia Services can be shared at your own discretion through social media outlets such as Facebook and Twitter. Please note that any Personal Information collected through the Sinopia Services that you decide to share on these social media outlets will be governed by the terms of use and privacy policies of those social media outlets.

e.     Legal. We reserve the right to make disclosure involving your Personal Information if we have a reasonable belief that disclosure to a third party, or investigator, is necessary for us to comply with law enforcement, search warrant, subpoena, judicial proceeding, or other legal process. We may also disclose your Personal Information to protect the reputation, rights or property of Sinopia, users of the Sinopia Services, or members of the general public. We may also disclose your Personal Information if we have a reasonable belief that disclosure is necessary to prevent or identify possible fraud or other wrongdoings involving the Sinopia Services, or to protect your safety or the safety of others.

Any other information that we share with our Business Partners or other Third Parties, will require your explicit consent. We will request approval every time we wish to share such information, and will allow you to opt-out.

4. LINKS

The Sinopia Services may contain links to Third Party websites that are not governed by this Privacy Policy. When you click any one of those links, you are contacting another website or internet resource. We have no responsibility or liability for, or control over those other websites or internet resources, or their collection, use disclosure of your Personal Information. We recommend you examine the privacy policies of those sites to learn how your information may be collected, used, shared and disclosed.

5. COOKIES

We, and Third Parties, including our partners, affiliates, and service providers, may use cookies. Cookies are pieces of information or data sent to your browser and stored on your device for record-keeping purposes. Cookies tell your device that you have visited our website before and help make your visit more personal so that you do not need to re-enter certain information. We do not connect this information to your Personal Information.

We, and Third Parties, including our partners, affiliates, and service providers, may use web beacons/pixel tags, log files, local shared objects, barcodes, session ID, and other technologies to collect certain information about users of the Sinopia Services, interactions with our applications, websites, emails and online advertisements. For example, we may collect your browser type, device type and its operating system, viewed webpages, links that are clicked, IP address, sites visited before coming to our website, emails we send that you open, forward, or click through to our website. The use of cookies by Third Parties, including our partners, affiliates, and service provides, is not covered by our Privacy Policy.

You may disable cookies and similar technologies through settings on your device or internet browser. Note that the opt-out will only apply to the device or browser that you are using when you elect to opt-out. Furthermore, it is important to note that you may not be able to use certain features of the Sinopia Services if you choose not to accept cookies.

6. CHILDREN

Children under the age of 18 should always get permission from their parents before sending information over the internet. We will not encourage a child under the age of 18, to visit, access, or otherwise use the Sinopia Services. You must be at least 18 years of age to use the Sinopia Services, and to make a donation through the Sinopia Services. If we suspect any interaction with the Sinopia Services to have been accidentally or deliberately caused by someone under the age of 18, we will immediately suspend or terminate that use, or content.

7. SECURITY AND DATA RETENTION

We will take all reasonable security measures to store and maintain Personal Information, including passwords. We will take all reasonable security measures to protect it from loss, misuse, alteration, and destruction by any unauthorized third party while it is under our control. However, you are in control of the Personal Information that you enter, transmit or display in connection with your use of the Sinopia Services, and therefore you are solely responsible for the consequences of any such action. While we will make reasonable efforts to protect Personal Information, and passwords, no transmission of data over the internet is entirely secure. Therefore we cannot guarantee its absolute security.

The Personal Information that you provide to us may be transferred outside of Canada for processing and storage. We, or our service providers may store Personal Information on servers located in other jurisdictions, including the United States. Please note that privacy laws in such jurisdictions may differ from Canadian privacy laws and in some jurisdictions your Personal Information may be accessed by law enforcement authorities or the courts.

Personal Information will be retained as long as necessary for the fulfillment of the purpose for which it was collected and for a reasonable time thereafter or for so long as we are required to maintain such information by law or other applicable rules or regulations. Sinopia does not store credit card information on our services, and this information is governed by the privacy policies of our payment processing partners.

8. PREFERENCES

It is our policy to provide you with notifications for service related purposes via email. By providing Sinopia your email address, we will send you service related notices, including any notices required by law, in lieu of communication by postal mail. We may also send you messages, such as updates, user communications, newsletters, or offers. We will notify you through email of every payment made via the Sinopia Services.

You may opt-out of emails at any time through the unsubscribe feature located at the bottom of the email, however Sinopia reserves the right to email you certain notices about your use of the Sinopia Services, regardless if you opt-out from other voluntary email communications.

9. QUESTIONS AND CONCERNS

Any of your questions, or complains with respect to this Privacy Policy should be directed to: Herohelp@sinopiacomics.com

10. UPDATES

We reserve the right to change or update portions of this Privacy Policy at any time by posting a new version on the website www.sinopiacomics.com. If you continue to access or use the Sinopia Services after the changes are in effect, you agree to be bound by the revised Privacy Policy. The effective date of this Privacy Policy will be posted at the top of the page.