Effective Date: Oct 19, 2020
Types of information we collect
INFORMATION YOU VOLUNTARILY SUPPLY
We and our Service Providers (defined below) collect and store information that you voluntarily supply to us while using our Services. For example, we collect information when you register an account, sign up for our newsletters, subscribe to our content (such as our comics and podcasts), participate in a Promotion (defined below), post on our Services, apply for a job, or otherwise communicate with us. The information we collect includes personal data, which is information relating to identified or identifiable natural persons. In accessing and using our Services, you may have the opportunity to voluntarily submit some or all of the following types of information:
• Contact information, including your first and last name, email address, and postal address.
• Credentials, including your passwords, password hints, and similar security information for authentication and account access.
• Payment card information, including your card number and associated security code;
• Demographic information, including your age and gender.
• Profile information, including your username, interests, and favorites.
• Resume information, including your employment history, transcript, writing samples, and references as necessary to consider you for a job opening.
• Information you include in correspondence you send to The Nib or one of the contributors or journalists whose work appears on our Services.
• Information you include in comments you post on any of our Services.
You may choose to voluntarily submit information to us through the Services that we do not request, including personal data, and, in such instances, you are solely responsible for such information.
Also, if you make information public through our Services, such as in response to one of our posts, other people will have access to that information. Please think carefully before making information public as you are solely responsible for that information. Once you have posted information, you may not be able to edit or delete such information; however, data subjects in Europe have additional rights as set forth in “Your rights and choices” below.
INFORMATION THAT IS AUTOMATICALLY COLLECTED
We and our Service Providers collect and store information that is generated automatically by your device as you navigate through our Services. Some examples of data we automatically collect include the following:
• Device connectivity and configuration data, including the type of device you’re using (computer, mobile phone, tablet, etc.), the operating system running on that device, the type and version of browser software you’re using, the resolution of your computer monitor or other device display, and the screen colors available on your device.
• Service use data, including data about the features you use, the pages you visit, the emails and advertisements you view, the website that referred you, the time of day you browse, and your exiting pages.
• Device location data, which can be precise if you give us your consent (e.g., latitude or longitude data) or imprecise (e.g., location derived from an IP address or data that indicates a city or postal code level).
• Device identifiers, including your IP address and mobile Ad ID (e.g., IDFA or AAID).
In certain circumstances, we may need to transmit or display to others your personal data along with information pertaining to your viewing habits of video content. By using the Service, you consent to our doing so.
Logs, cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, device fingerprinting, in-app tracking methods, and other tracking technologies now and hereafter developed (“Tracking Technologies“) may be used to collect information about your interactions with the Services and content, including information about your browsing and activity behavior:
- Log Information: Log information is data about your use of the Services, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data, which is stored in log files.
- Information Collected by Tracking Technologies: Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, device fingerprinting, in-app tracking methods, and other tracking technologies now and hereafter developed (“Tracking Technologies“) may be used to collect information about your interactions with the Services and content, including information about your browsing and activity behavior.
- Cookies: Cookies are small files that your web browser places on your hard drive for record-keeping purposes. A cookie may be a session ID cookie or tracking cookie. Session cookies make it easier for you to navigate the Services and expire when you close your browser. Tracking cookies help in understanding how you use Services, personalizing your experience, and providing you with advertisements, and remain longer. Cookies may remain on your hard drive for an extended period of time. If you use your browser’s method of blocking or removing cookies, some features and functionalities of the Services may not work. The Services may associate some or all of these types of cookies with your devices.
- Web Beacons (“Tracking Pixels”): Web beacons are small graphic images, also known as “internet tags” or “clear gifs,” embedded in web pages and email messages. Web beacons may be used to provide information about how our visitors use our Services and how they interact with our email newsletters and with our stories that appear on other websites.
- Embedded Scripts: An embedded script is programming code designed to collect information about your interactions with the Services. It is temporarily downloaded onto your device from our web server or a third party with whom we work, is active only while you are connected to the Services, and deleted or deactivated thereafter.
- Location-identifying Technologies: GPS (global positioning systems) software, geo-filtering, and other location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your location.
- In-App Tracking Methods: There are a variety of tracking technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifier, or other identifiers such as mobile Ad IDs to associate app user activity to a particular app and to track user activity across apps.
Some information about your use of the Services and certain Third-Party Services may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Services and certain Third-Party Services. For further information on Tracking Technologies and your rights and choices regarding them, please see “Third-Party Services, Analytics, and Advertising” and “Your rights and choices” below.
INFORMATION FROM OTHER SOURCES
• Data brokers from which we purchase demographic data to supplement the data we collect.
• Social networks when you reference our Services or grant permission to us to access your data on one or more of these services.
• Partners with which we offer co-branded services or engage in joint marketing activities.
• Publicly-available sources such as data in the public domain.
For further information on Third-Party Services, please see “Third-Party Services, analytics, and advertising.”
HOW WE USE COLLECTED INFORMATION
We use the information we collect from visitors to our Services, including personal data, for our legitimate interests, including to:
• Manage our Services and content.
• Deliver content to our users.
• Provide products and subscriptions.
• Communicate with you for customer service purposes.
• Send you technical notices, updates, and security alerts, and inform you of important changes or additions to our Services.
• Prevent and address fraud, breach of policies or terms, and threats or harm.
• Monitor and analyze trends, usage, and activities to better understand and serve our audience.
• Improve our Services and the services and features we offer.
• Tell you about other products and services offered by The Nib or its affiliates and products and services of selected others that we think may be of interest to you.
We also use information with your consent, including to:
• Verify your eligibility and deliver prizes in connection with Promotions you have entered.
• Tailor advertising based on your interests.
• Fulfill any other purpose disclosed to you and with your consent.
We may use information that does not identify you (including information that has been de-identified) without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see “Your rights and choices” below.
Disclosure of information
Our agents, vendors, consultants, and other service providers (collectively “Service Providers“) may receive or be given access to your information, including personally identifying information and Usage Information, in connection with their work on our behalf. For example:
- When we send you email newsletters and other communications, we may use a Service Provider to send the emails on our behalf.
- When you purchase a product or subscribe to our Services, we may use payment processors and fulfillment partners.
These Service Providers are prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.
We also share information about you, including personal data, as follows:
- With our affiliates for internal business purposes, including customer support, marketing, and technical operations.
- With our business partners in connection with offering you co-branded services, creating and promoting or content (such as comics and podcasts), or engaging in joint marketing activities.
- With our affiliates, and other third parties for their own direct marketing purposes.
- With third parties for purposes of facilitating your requests (such as when you choose to share information with a social network about your activities on the Services) and in connection with tailoring advertisements, measuring and improving our Services and advertising effectiveness, and enabling other enhancements.
- If required to do so by law or if, in our judgment, such disclosure is reasonably necessary to comply with legal process, to enforce our Terms of Service, or to protect the rights, property, or personal safety of visitors to our Services, our employees, or others.
- In the event that we sell some or all of our assets, or one or more of our Services is acquired by another company (or during negotiations), information about you may be among the transferred assets.
- For purposes disclosed to you and with your consent.
We may offer sweepstakes, contests, surveys, and other promotions (each, a “Promotion“) jointly sponsored or offered by third parties that may require submitting personally identifying information. If you voluntarily choose to enter a Promotion, your personally identifying information, including personal data, may be disclosed to third parties for administrative purposes and as required by law (e.g., on a winners list). By entering, you agree to the official rules that govern that Promotion, and you permit, except where prohibited by applicable law, the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.
Without limiting the foregoing, in our sole discretion, we may share aggregated information that does not identify you or de-identified information about you with third parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “your rights and choices” below.
Third-party services, analytics, and advertising
Our Services include hyperlinks to websites, locations, platforms, and/or services operated by third parties (collectively, “Third-Party Service(s)“). These Third-Party Services may use Tracking Technologies to independently collect information about you and may solicit information from you.
You may interact with content on our Services through social media sharing tools and other social media platforms and services we use (collectively, “Social Features“). Examples of Social Features include “liking” or “sharing” our content and otherwise connecting our Services to a Third-Party Service. You may also interact with content on our Services, such as comics and podcasts, through platforms that host or embed them through our Services. These Third-Party Services may share the information they collect, including personal data, with us. We do not control the information that these Third-Party Services collect when you use their tools, nor do we control how the third parties that operate the Third-Party Services use any information they collect. We encourage you to review their privacy policies before using their tools, which can be found at their respective sites. If you’d prefer that these Third-Party Services not collect information about the content you share and use, we suggest that you not use their tools. Also, if you post information on a Third-Party Service that references our Services (e.g., by using a hashtag associated with The Nib in a tweet or status update), your post may be used on or in connection with our Services.
To help us understand how users are using our Services and to help us improve our Services, we may deploy our own analytics engine in addition to engaging third-party analytics Service Providers to collect aggregate information on our audience and how our audience uses our Services (for example, information on traffic to various pages within our Services). These Service Providers may use this information for purposes such as evaluating your use of the Services, compiling statistic reports on the Services activity, and providing other services relating to Services activity and other internet usage. We may use services to provide shortened uniform resource locators (URLs: the “addresses” of individual web pages) so our content can be shared more easily. These services collect information as our shortened URLs are shared and clicked on and may make some of that information available to us.
We may also engage and work with third parties to serve advertisements on the Services and/or on Third-Party Services. These third parties may use Tracking Technologies to tailor ads to your interests based on your browsing of the Services and elsewhere on the internet, sometimes referred to as “interest-based advertising” and “online behavioral advertising (“Interest-based Advertising“), which may include sending you an ad on a Third-Party Service after you have left the Services (i.e., “retargeting”).
In addition, we may serve ads on third party services that are targeted to reach people on those services that are also identified on one of more of our data bases (“Matched List Ads“). This is done by matching common factors between our data bases and the data bases of Third Party Services. For instance, we may use such ad services offered by Facebook or Twitter. To opt-out of receiving Matched List Ads, please contact the applicable Third-Party Service. If we use Facebook to serve Matched List Ads on Facebook services, you should be able to hover over the box in the right corner of such a Facebook ad and find out how to opt-out. We are not responsible for such third-party services’ failure to comply with your opt-out instructions.
For further information on Tracking Technologies and your choices regarding them, please see “Information Collected Automatically” above and “Your rights and choices” below.
Your rights and choices
ACCESSING AND CHANGING YOUR ACCOUNT INFORMATION
You may access, update, or remove certain account information we have about you that you have voluntarily submitted to us through the Services, such as your name and email address, by sending an email to us here. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Data subjects in Europe have additional rights as set forth in “Your European privacy rights” below.
TRACKING TECHNOLOGIES GENERALLY
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. However, if you don’t accept cookies, you won’t receive the benefits that cookies provide. For example, a cookie may enable you to resume a video you watched in a previous visit. Further, cookies may be necessary for services to work as intended, such as keeping you logged in to a secure part of our site. Browsers offer different functionalities and options so you may need to set them separately. Please be aware that your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
You can reset your mobile Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. For information on how to do this on Apple devices, visit Apple.com or https://support.apple.com/en-us/HT202074. For information on how to do this on Android devices, visit Google.com.
The location data collected through an app depends on your device settings and app permissions. If you opt-in to collection of precise location data, you can opt-out at any time by changing your app permissions in your device settings. You can stop collection of all location data via an app by uninstalling the app.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
ANALYTICS AND ADVERTISING TRACKING TECHNOLOGIES
Some of the advertisers and Service Providers that perform advertising-related services for us and our partners participate in the Digital Advertising Alliance (“DAA“) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices, and http://www.aboutads.info/appchoicesfor information on the DAA’s opt-out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI“). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt-out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). The Nib is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
In order to opt out of Interest-based Advertising under the Twitter Website Conversions Objective Beta Program, you must both (a) use the Do Not Track functionality in your web browser; and (b) follow the instructions at http://www.aboutads.info/choices, http://www.networkadvertising.org/choices/, or any successor or related websites where users can access the interest-based opt-out mechanisms provided by the companies participating in such programs.
You can opt-out of receiving certain promotional communications (emails, text messages, and push notifications) from us at any time by (i) for emails, following the instructions as provided in emails to click on the unsubscribe link, or contacting us here with the word UNSUBSCRIBE in the subject field of the email; (ii) for text messages, texting “STOP” in response to any text message you receive or contacting us here and specifying you want to opt-out of text messages; and (iii) for push notifications or in-app messages, adjusting the permissions in your mobile device. Please note that your opt-out is limited to the email address, phone number, or device used and will not affect subsequent subscriptions or, for emails, non-promotional communications, such as those about your account, transactions, servicing, or The Nib’s ongoing business relations. For text messages and push notifications, we will not send you communications unless we first obtain your opt-in consent.
Your California privacy rights
California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt-in to, or opt-out of, this type of sharing. The Nib may share personal information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please email us here or send us a letter to Inkwell Comics LLC, 11 NE M L King Blvd Ste 202, Portland, OR 97232. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are not required to respond to requests made by means other than through the provided email address or mail address.
Your European privacy rights
To exercise any of these rights, contact us as set forth in “Contact us” below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
If you have any issues with our compliance, you have the right to lodge a complaint with a European supervisory authority.
Our Services are not directed at children under the age of 13 and we do not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA“) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe we have collected information in a manner not permitted by COPPA, please email us here or send us a letter to Inkwell Comics LLC, 11 NE M L King Blvd Ste 202, Portland, OR 97232, and we will remove such data to the extent required by COPPA.
We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. However, no physical or electronic security system is impenetrable. We cannot guarantee the security of our servers or databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us or our third-party service providers over the internet.
We are based in the United States and the information we collect is governed by United States law. Our databases are located within the United States and other jurisdictions. If you access our Services from outside the United States, by providing data to us, you consent to transfer, processing, and storage of that data in the United States and other jurisdictions. Data protection laws in the United States and other jurisdictions may be different from those of your country of residence. If your data is collected in Europe, we will transfer your personal data subject to suitable safeguards, such as standard contractual clauses.
By email: email@example.com
Inkwell Comics LLC ATTN: Privacy, 11 NE M L King Blvd Ste 202, Portland, OR 97232