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Privacy and Policy

The Midtown Advantage

This privacy notice tells you the types of information we collect about you when you visit our Site https://www.midtowncomics.com (the “Site”) and use our products and services or which we otherwise obtain directly from you, how we use that information, and the instances in which we share your information. This privacy notice may change from time to time so please check this policy regularly.

For the purposes of this privacy notice, the term “personal data” means any information which identifies you or which allows you to be identified when combined with other information.

 

Important information and who we are

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact Details

Our full details are:

Full name of legal entity: Midtown Comics Online, Inc.

Title of data privacy manager: Data Protection Representative

Email address: dataprotection@midtowncomics.com

Postal address: Midtown Comics Online, Inc., 1403 Fourth Avenue, New Hyde Park, NY 11040

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 24th May 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

The data we collect about you

We may collect, use, store data about you which we have grouped together follows:

  • Identity Dataincludes first name, maiden name, last name, username or similar identifier and title.
  • Contact Dataincludes billing address, email address and telephone numbers.
  • Transaction Dataincludes details about payments to and from you and other details of products you have purchased from us including the card used for a particular transaction
  • Technical Dataincludes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Site.
  • Profile Dataincludes your username and password, purchases or orders made by you.
  • Marketing and Communications Dataincludes your preferences in receiving marketing from us.

We also collect and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Direct interactions.You may give us your Identity and Contact by filling in forms or by corresponding with us by post, phone, email, online or otherwise. This includes personal data you provide when you:
  • Give us feedback, subscribe to our newsletters
  • Automated technologies or interactions.As you interact with our Site, we may automatically collect Technical Data about your equipment and Usage Data about your browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see section 5 below (“Cookies”) for further details.

How we use your personal data

We will only use your personal data when the law allows us to.

We do not share your data with any third party.

Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

You have the right to withdraw consent to marketing at any time by contacting us.

 

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

  • Purpose/Activity
  • Type of data
  • Lawful basis for processing including basis of legitimate interest
  • To register you as a new customer/user
  • (a) Identity

(b) Contact
(c) Profile

  • (a) Performance of a contract with you (where you are using the Site as an individual)

(b) Necessary for our legitimate interests (where you are using the Site as an authorized user of one of our enterprise customers, in order for us to perform our contract with that customer, to optimize your on boarding and user experience by ensuring you receive relevant instructions and tutorials regarding the use of our Site and products)

  • To process and deliver orders for our products including:

(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c) Identity
(d) Contact
(e) Transaction

(f) Marketing and Communications

  • To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
c) Dealing with your enquiries and complaints

  • (a) Identity

(b) Contact
(c) Profile
(d) Marketing and Communications
(e) Performance of a contract with you
(f) Necessary to comply with a legal obligation
(g) Necessary for our legitimate interests (to keep our records updated and to study how customers use our Site, products and services)

  • To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  • (a) Identity

(b) Contact
(c) Content
(d) Technical

  • (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

(b) Necessary to comply with a legal obligation

  • To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  • (a) Identity

(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
(g) Content

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased products or services from us or if you provided us with your details when you placed an order or subscribed for the marketing emails, you have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Cookies

Our Site uses cookies and similar technologies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and allows us to improve our Site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

The types of cookies we use on our Site are:

  • Strictly Necessary Cookies.We use Strictly Necessary Cookies to operate our Site. These cookies are essential to enable you to move around the Site, use its features and to log into secure areas of the Site.
  • Functionality Cookies.We use Functionality Cookies to recognize you when you return to our Site. This enables us to personalize our content for you, greet you by name and remember your preferences and various settings on our Site
  • Analytical/Performance Cookies.These cookies collect information about how many people are using our Site and how they are moving around it when they are using it. For example, the pages visited most often, how people are moving from one link to another, and if they get error messages from certain pages. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Site may become inaccessible or not function properly.

Please contact us if you want further information on the specific cookies used by us.

 

Disclosures of your personal data 

We do not share your data with any third party.

 

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach within 72 hours of discovering the breach and where we are legally required to do so.

Data retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

You can request further details of retention periods for different aspects of your personal data by contacting us.

In some circumstances you can ask us to delete your data: see “Your legal rights” below for further information.

 

Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

  • Request accessto your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correctionof the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasureof your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processingof your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
  • Request restriction of processingof your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Withdraw consent at any timewhere we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests as soon as possible. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 


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