PRIVACY

Welcome to MASTERMIND COMICS

MASTERMIND COMICS™ Policies for Handling Personal Information

Last Modified: May 13, 2020
The MASTERMIND COMICSUNICORP. (hereinafter “the company”, “we”, “our” or “us”) handles MASTERMIND COMICS users’ personal information according to the following policies.Articles of personal information collectedYou can create a MASTERMIND COMICS account using your email address, Nickname and password. If you use an email address to create an account, you cannot change the email address associated with the account later. You may, however, edit your Nickname and password at any time.
The company also supports various social networking service (“SNS”) logins for convenient member registration and service provision, and during this process processes the following personal information.
• – Register with MASTERMIND COMICS, Facebook, Twitter, Google and Apple: ID, Nickname or display name
If you choose to create an account using an SNS login, you can still add an email address and/or Nickname to your profile. This is optional and you can edit your email address and Nickname at any time.
We also collect the email address of applicants to MASTERMIND COMICS, and reserve the right to collect contact information and item delivery information when you contact us or if you are sent items during a special event.
When you use our service, your network information(IP address, nation based on IP address, types of network, etc.), records of service use(frequency of use, coin usage, visited or consumed product, etc.), device information(make, model, OS, etc.) are generated and may be collected.
Methods of collecting personal information

The company collects the following information in order to provide you with its services.

  • – Information submitted directly by users when registering for or using the MASTERMIND COMICS service
  • – Information provided to us by affiliated companies
  • – Information automatically generated and collected in the course of using the service

Use of 3rd Party Analytics

The company uses a tool called “Google Analytics” to collect information about use of this site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. The company uses the information it gets from Google Analytics only to improve this site. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. The company does not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. To-opt out of Analytics for the web, visit the Google Analytics opt-out page and install the add-on for your browser [here].

The company uses DoubleClick cookies. The cookie ID is used for the purpose of analyzing the effectiveness of advertisements and not displaying the same ads over and over again. Users can stop the use of DoubleClick cookies by visiting and changing Google’s advertisement settings [here].

The company also uses other 3rd party analytics for the same reasons stated above for Google Analytics, such as Facebook Analytics for Apps and Tune/Branch. These companies help the company understand your use of our service. In association with them, the company may collect your non-personal information such as IP address, app installation, age, language, device information. These are for internal use only and the company does not combine this information with what it gathered through your use of our service for identifying purposes. Documentation for Facebook Analytics for Apps can be found [here] and Facebook’s data policy can be found [here]. Privacy policy for Tune/Branch can be found [here] (Tune) / [here] (Branch).

Some of the advertisements you see on MASTERMIND COMICS are tailored to your interests and based on your online browsing activity. You may opt-out these ‘tailored advertisements’ from third-party ad providers who are members of The Network Advertising Initiative (NAI) and the Digital Advertising Alliance (DAA) by clicking [here]. You may also find additional details on how to opt-out on your mobile devices [here]. Please note, opting out of interest-based advertising does not mean you will no longer see advertising on our platform. Upon opting out, the company or companies which you opt out from will no longer show advertisements that have been tailored to your interests.

The purpose of collecting and using personal information

The company makes use of collected information for the following purposes.

  • – Helping users make use of the service more smoothly
  • – To distinguish users and prevent improper usage of the site
  • – To generate statistical data pertaining to usage of the service
  • – To conduct surveys and analyses necessary for improving the service
  • – To draw tickets and send out prizes for campaigns and events
  • – To confirm a user’s identity when we receive an inquiry and to be able to respond to it
  • – For payment and billing when a user purchases a product or uses a service which is not free
  • – To send users important notifications when necessary
  • – To disseminate advertisement information for events

Sharing and provision of personal information

As a rule, the company does not share user information with external parties without prior consent from users. However, the following instances are exceptions.

  • – When users have agreed to information sharing
  • – When it is required by law

Consignment of personal information handling

The company has consigned the collection of personal information for the provision of its services in the following manner.

Information concerning the consigned companies and their duties:

(1) Customer inquiries: Mastermind Comics

(2) Infrastructural operations and prevention of inappropriate usage: Business Platform Inc.

(3) System Operations and Data Analysis :Mastermind Comics

(4) Payment processing :Mastermind Comics

The rights of users and legal representatives and how to exercise them

  • – Users and legal representatives may at any time view or edit their own registered personal information or that of a minor who is less than 13 years of age. They may also request the deletion of their account.
  • – When a user requests an amendment to incorrect personal information, we do not use or provide the personal information until it has been corrected. In addition, if incorrect personal information has already been provided to a third party, we notify the third party immediately of the amendment to be made and ensure that the information is corrected.
  • – The company processes personal information suspended or deleted upon the request of a user or legal representative as per the section “Period of storage and usage of personal information.” We ensure that the information cannot be viewed or used for any other purpose.
  • [For U.S Residents Only]
    In connection with the MASTERMIND COMICS service, we do not knowingly solicit or collect personal information from children under the age of 13. If we learn that we have collected personal information from a child under age 13, we will promptly delete that information. If you believe that a child under age 13 may have provided us with personal information, please contact us as specified in the HOW TO CONTACT US section of this Privacy Policy.

Installation, management and refusal of automatic personal information collection devices

  • – Purpose of using cookies
    We use and analyze cookies from services used or websites visited by users in order to provide users with optimal service.
  • – Installing, managing and refusing cookies
    The user has the right to choose their cookie settings. By using the options provided by their browser or OS, the user may allow or refuse cookie storage. However, when cookie storage is refused, users may experience difficulties using certain services which require login.

Period of storage and usage of personal information

As a rule, the company eliminates records of users’ personal information once the purpose of their collection and usage is accomplished. However, in cases where records need to be stored according to the company’s internal policies or relevant legislature, we reserve the right to store personal information for a certain period of time.

The process and methods of eliminating personal information

The process and methods of eliminating personal information are as follows.

  • – Process of elimination
    Once the purpose of information entered by users to make use of the service has been accomplished, it is stored for a certain period of time and then eliminated as per the company’s internal policies and relevant legislation. Unless it is stipulated by law, the personal information will not be used for anything other than storage.
  • – Methods of elimination
    Personal information printed on paper is shredded, and information stored electronically is permanently deleted so as to prevent it from ever being used again.

For inquiries concerning the protection of personal information

If you have any questions, concerns or inquiries concerning the Policies for Handling Personal Information, you may send them to our personal information management department at: info@mastermindcomics.net

Scope of effectiveness

The Policies for Handling Personal Information do not apply to information collected by other companies through linked pages within the service.

Amendments to the Policies for Handling Personal Information

If any additions, deletions or amendments are made to the Policies for Handling Personal Information, a notification will be posted on the “Notice” page at least 7 days prior to any changes made. However, for significant changes made to user rights such as the collection and utilization or provision to third parties of personal information, we will post a notification 30 days in advance.

MASTERMIND COMICS™ Privacy Policy for EU residents

** If you are a user having your usual residence in EU, this Policy shall apply.

INTRODUCTION
MASTERMIND COMICS (hereinafter “the company”, “we”, “our” or “us”) is concerned about the protection of your personal information and is committed to the respect of your privacy. The purpose of this privacy policy is to provide you with clear and transparent information on how we collect, process, store, share and transfer any information that can directly or indirectly identify you (hereinafter “personal information”).

DATA CONTROLLER
MASTERMIND COMICSUNICORP. whose head office is located in Republic Texas, is the data controller of the processing activities relating to your personal information as further described in this privacy policy.

KEY INFORMATION
We collect certain of your personal information through our application and/or website in particular to allow you to register to our services, to provide you with the services you subscribed to and also for marketing purposes when you gave your consent. We mostly collect identification and usage information (i.e. Email address, name, nickname, password, social networks profile information when you decide to register via any of your existing social networks account. The categories of information we may collect as part of the services and the corresponding purposes and related legal basis are detailed in the table set out under section 2 of the privacy policy.
You have rights of access to and rectification or erasure of your personal data and to restrict or object to its processing, as well as the right to data portability, which you can exercise at any time by making a written request to the following address: [insert the relevant email address].You also have the right to lodge a complaint about our processing of your personal data with the competent supervisory authority, such as the French Data Protection Authority (CNIL). To the extent the French data protection legislation is applicable, you have the right to establish instructions in respect of the retention, the deletion and the transmission of your personal data after your death. Where the processing of your personal data is based on consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing which were based on consent before its withdrawal. More detailed information related to your data protection rights is available under section 4 of the privacy policy.

CHILDREN
Children under the age of 15 years old cannot subscribe directly to MASTERMIND COMICS services without verifiable parental prior consent or authorization obtained through the “Approval Verification from Parents” process displayed before being able to register. We do not intentionally collect personal information from children under the age of 15 years old. If we realise that we have collected personal information of a child under 15, or equivalent minimum age depending on jurisdiction, outside the above mentioned case, we will delete any personal information related to such child. For more information on the authorised processing of children’s information, read more under section 10 of the privacy policy.
CONTACT
Should you have any questions or concerns on this privacy policy or on the processing of your personal information, feel free to contact us by sending an email to our (i) Data Protection Officer (DPO) at the following address info@mastermindcomics.net (ii) European data protection representative at the following addressinfo@mastermindcomics.net. For more information on the way to contact us for any privacy questions or complaints, please see section 11 of this privacy policy.

1. PERSONAL INFORMATION WE COLLECT AND PROCESS

We collect certain of your personal information through our application and/or website to be able to provide you with the best experience of the services and also for marketing purposes under your consent. We mostly collect identification and usage information.

The categories of information we may collect as part of the services and the corresponding purposes and related legal basis are detailed in the table set out under section 2 below.

2. PURPOSES AND LEGAL BASIS FOR THE PROCESSING OF YOUR PERSONAL INFORMATION

Transaction Data / Payment details: we do not collect or process any transaction data concerning you (e.g. credit card details). Such information is only collected and processed through Apple’s App Store and Google Play Store. The only information that Apple and Google may share with us is technical information that does not allow us to identify you (e.g. transaction number), and is only processed to validate the transactions.

  1. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

3.1 Personal information you provide to us directly

When you use our services, you share information with us, some of which may be used to identify you. In particular:

Personal information required to register

The following information are required to subscribe to our services and to be able to create an account. If you do not want to share this information with us, we will not be able to provide you with the services offered in the application and/or on the website and you will not be able to create your account.
– Your date of birth;
– Your email address;
– Your nickname.

3.2 Personal information we receive from social networks when registering to our services

When you choose to login via existing social networks services, the relevant social network may allow us to access to or share with us certain information about you:
– If you use your existing Facebook account to login, Facebook will share with us your name, your account’s profile picture and your email address;
– If you use your existing MASTERMIND COMICS account to login, MASTERMIND COMICS will share with us information relating to your MASTERMIND COMICS profile, name displayed in app, your accounts profile picture and your status message (e.g. “busy”, “at work”, etc);
– If you use your existing Twitter account to login, Twitter will share with us your pseudonym, email address and your account’s profile picture;
– If you use your existing Google account to login, Google will share with us your email address or telephone number and your account’s profile picture; and
– If you use your existing Apple account to login, Apple will share with us your display name and email address.

3.3 Personal information we collect automatically through the use of cookies

 

Please refer to section 9 of the privacy policy

  1. YOUR RIGHTS

4.1 Your data protection rights

 

 

Your right of access: you have the right to ask us whether or not we are using or storing your personal information. You can also ask us for copies of your personal information.
Your right to rectification: you have the right to ask us to rectify information you think is inaccurate. You also have the right to complete information you consider is incomplete.
Your right to erasure: you have the right to ask us to erase your personal information in the following circumstances: (i) we no longer need your personal information, (ii) you initially consented to the use of your personal information, but have now withdrawn your consent, (iii) you have objected to the use of your personal information and your interests outweigh those of our company, (iv) we have collected or used your personal information unlawfully; and/or (v) we have a legal obligation to erase your personal information.
Your right to restriction of processing: you have the right to ask us to restrict the processing of your personal information in the following circumstances: temporarily limit when (i) you have challenged the accuracy of your personal information; or (ii) you have objected to the use of your personal information and /or limit if (i) we processed your personal information unlawfully without you wishing to delete it; and (ii) we no longer need your personal information but you wish us to keep it in order to defend or exercise legal claims.
Your right to object to processing: you have the right to object to the processing of your personal information if we are using your personal information for (i) a task carried out in the public interest, (ii) our legitimate interests, (iii) scientific or historical research or statistical purposes; or (iv) direct marketing.
Your right to data portability: this right applies to personal information you have provided to us and where the processing is automated and based on your consent or made under a contract. You have the right to ask us, if technically feasible, to transfer your personal information to another organization or directly

provide it to you in a way accessible and machine readable.
You also have the right to withdraw consent at any time where the processing is based on your consent, without affecting the lawfulness of processing based on consent before such withdrawal.
You have the right to lodge a complaint before a supervisory authority – In France, the French data protection authority (“Commission Nationale de l’Informatique et des Libertés”).

Where French data protection law is applicable, you also have the right to set guidelines for the retention and communication of your personal information after your death.

4.2 How to exercise your rights

– If you are based outside of the European Union, you can exercise any of the above listed rights by sending an email to our Data Protection Officer (DPO) at the following address info@mastermindcomics.net
– If you are based in the European Union, you can exercise any of the above listed rights by sending an email to our European data protection representative at the following address info@mastermindcomics.net
– You can also directly exercise any of the above listed rights in the application by contacting us through the section [“Your rights”] directly available through the settings of the application.

HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

MASTERMIND COMICS has implemented and is maintaining adequate technical, physical and organizational measures (e.g. limited access, internal security and IT policies, back-up plans) to ensure the confidentiality and security of your personal information, in particular to protect personal information against accidental or unlawful destruction or accidental loss, damage,alteration, unauthorized disclosure or access as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing.

  1. HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION?

 

 

 

 

 

MASTERMIND COMICS will immediately delete your personal information once the purpose for which they have been collected and processed is attained. In other words, we will not keep your personal information for longer than necessary.

For more information on specific retention periods applicable to specific purposes, please refer to our data retention policy.

  1. WHO HAS ACCESS TO YOUR PERSONAL INFORMATION

7.1 Access and processing of your personal information by our trusted affiliated companies

As a global organization, personal information we collect may be shared with other companies of the group for administrative, technical and operational purposes and necessary for the provision of the services offered through MASTERMIND COMICS’s application and website. In particular,
– Mastermind ComicsUnincorp has access to and will process your user ID, your IP address and your email address for the management of your relationship with MASTERMIND COMICS and for the management of your inquiries and requests;
– Mastermind ComicsUnincorp .has access to your user ID, your IP address and your email address for operational and analysis purposes;
– Mastermind ComicsUnincorp . for infrastructural operations and the prevention of misuse of the services;
– Mastermind ComicsUnincorp has access to and will process your device identification key number and unique value given to you as subscriber of services for payment processing purposes, in particular in order to enable the validation of transactions made through Apple Store and Google Play Store platforms

When trusted affiliated companies listed above are given access to your personal data, NMASTERMIND COMICS shall take the required contractual, technical and organizational measures to ensure that your personal information are only processed to the extent that such processing is necessary and only for the purposes set out above.

7.2 Access and/or processing of your personal information by trusted business partners

Based on your prior specific consent given on the registration page in the application or on the website, we will share your email address with the following trusted third parties in order for them to send you promotional offers and other marketing contents. This privacy policy does not cover how these trusted third parties, acting as independent data controllers, will process your personal information. We recommend you to read each third party’s relevant privacy policy.

  1. TRANSFERS OF PERSONAL INFORMATION OUTSIDE OF THE EUROPEAN ECONOMIC AREA

 

As our company is based in Korea, your personal information will be transferred and stored in our servers located in Texas.

In addition, for the purposes set out under section 7.1 of this privacy policy, we will give access to your personal information to our affiliated companies all located in Texas.

These transfers are made in compliance with applicable data protection regulation and are based on appropriate safeguards in order to protect your personal information. In particular, we have entered into data transfer agreements including the model clauses approved by the European Commission with each recipient of your personal information located outside of the European Economic Area and not recognized as providing an adequate level of protection (whether within group or with our external business partners).

You have the right to receive a copy of such data transfer agreements by contacting us, as follows:
– If you are based outside of the European Union, you can exercise any of the above listed rights by sending an email to our Data Protection Officer (DPO) at the following address info@mastermindcomics.net
– If you are based in the European Union, you can exercise any of the above listed rights by sending an email to our European data protection representative at the following address info@mastermindcomics.net
– In any event, you can contact us in writing at the following address: MASTERMIND COMICS CORP. head office located in Republic of Texas.

 

  1. COOKIES

Cookies are small text files that are placed on your computer and devices by us when you use our application or visit our website. They are widely used in order to make the application and our website work, or work more efficiently, as well as to provide us with more information.

MASTERMIND COMICS uses cookies and other technologies (such as web storage) (collectively referred to as “cookies”) necessary for authentication and security purposes. We would also like to use optional cookies to provide personalized content and to improve our services based on how you use such services.

You can manage the use of optional cookies by clicking on the “cookie settings’ solution displayed when you open the application / visit the website and at any time through the cookie settings page available [here].

In any event, cookies will not be set for more than 13 months following which we will ask your consent again before setting again such cookies.

  1. CHILDREN’S PRIVACY

We do not provide services directly or proactively to children under the age of 16 years old nor do we intentionally collect their personal information. If we realize that we have collected personal information of a child under 16, or equivalent minimum age depending on jurisdiction, we will delete any personal information related to such child.

Therefore, before being able to login and/or register, we will ask you to provide age-related information in order to help us comply with data protection laws. In particular, we will request your date of birth to determine whether or not you are allowed to benefit from the services or we have to obtain verifiable parental consent from your parent or relevant holder of parental responsibility before allowing you to access and/or benefit from the services.

  1. HOW TO CONTACT US

 

– If you are based outside of the European Union, you can contact us by sending an email to our Data Protection Officer (DPO) at the following address admin@mastermindcomics.net
– If you are based in the European Union, you can contact us by sending an email to our European data protection representative at the following address admin@mastermindcomics.net
– In any event, you can contact us in writing at the following address: MASTERMIND COMICSUnicorp head office located in  Republicof Texas.

  1. LINKS TO OTHER WEBSITES

You may identify hyperlinks to access the websites of other organizations on our websites or in the content we provide to you (e.g. promotional email or events). Please note that this privacy policy does not cover how other companies will process your personal information. We recommend you to read the privacy policies applicable to such other websites.

  1. UPDATES AND CHANGES TO THE PRIVACY POLICY

We keep our privacy policy under regular review to ensure it is up to date and accurate in particular in accordance with the applicable data protection regulation.

In case of significant changes, we will inform you of such changes and provide you with a hyperlink to the updated privacy policy 30 days in advance. This information will be provided to you by email and will be made available through a pop-up window when opening the application or visiting the website again.

MASTERMIND COMICS™ Privacy Policy for Creators

** This section supplements the Privacy Policy and applies solely to creators. If not specified in this section, please follow the Privacy Policy.

Information We Collect

When you use  and/or we may need collect the following information:
– We may request that your PayPal ID or Patreon ID be linked to the Service.
– If you choose to provide us your PayPal ID, we may ask for additional information such as your Name (Legal Name/Business Alias), Full name/Business name, Country, Residency, Address, Postal code, E-mail, Signature and Tax ID (or Social Security Number when applicable) for tax processing purposes.

How We Use the Information We Collect

– Verify your identity to comply with applicable federal laws;
– Send emails relevant to your usage, as controlled by your email preference;
– Reply to your questions;
– Understand how you use the Service
– Conduct research and development to improve and develop future products;
– Comply with and enforce applicable law requirements, our statutory obligations (e.g., tax laws), relevant industry standards and our policies, including this Privacy Policy; and/or
– Prevent fraud and abuse