Privacy Policy

Release date: August 6, 2024
Effective date: August 6, 2024
Updated: August 6, 2024

SH TRELLEBORG STUDIO LOHI , LLC (hereinafter referred to as "the Company"), we attach great importance to the protection of user personal information and privacy, so we have formulated a privacy policy covering how to collect, store, use, share and protect user information, as well as the ways we provide you with to access, update, delete and protect this information. We hope to use this privacy statement (hereinafter referred to as "this Privacy Policy") to clearly introduce to you how we handle your personal information and other information.

This Privacy Policy is closely related to your use of Top Comic's products and/or services. Before using any of Top Comic's products and/or services, please read and fully understand the Privacy Policy (especially the bolded content) and make sure you understand our rules for handling your personal information (defined below) and other information, and make the choices you deem appropriate accordingly. If you disagree with any of the contents of this Privacy Policy, it means that you choose to give up using Top Comic's products and/or services, and please stop using Top Comic's products and/or services immediately. When you use any of Top Comic's products and/or services, it means that you agree and fully understand the entire contents of this Privacy Policy.

Introduction

This policy contains the following contents:

1. Instructions for collecting permissions
2. How do we collect and use your personal information and other information
III. Circumstances in which your personal information may be lawfully shared, transferred, or publicly disclosed
IV. User information collection instructions for third-party SDKs
V. How do we safely protect and store the information you provide?
VI. Protection of Minors’ Information
VII. Your Rights
VIII. Notice and Revision
IX. Applicable Law and Dispute Resolution
X. How to contact us

Special Tips

1. Thank you for your use and trust in Top Comic. We will continue to be committed to providing you with safer and more reliable services.

2. All products and services on the Top Comic platform (including all products or services of Top Comic) are subject to this Privacy Policy, but certain specific products and/or services will also be subject to specific privacy policies.

3. The privacy policies of the above-mentioned specific products and/or services constitute part of this Privacy Policy. If there is any inconsistency with this Privacy Policy, the privacy policies of the specific products and/or services shall prevail.

4. Unless otherwise expressly stated in this Privacy Policy, this Privacy Policy does not apply to products and/or services independently provided to you by a third party that are accessed through our products and/or services, such as websites that may contain third-party services or other websites linked to in our services. Please note that if you provide your personal information and other information to a third party when using its products and/or services, your information shall be subject to the third party’s privacy statement or similar policy, and we do not assume any legal responsibility for any third party’s improper use or disclosure of the information you provide.

1. Instructions for collecting permissions

【Access network permission】 The app needs this permission to load necessary data from the Internet.
[Read location permission] The SDK requires this permission to provide anti-cheating services by collecting location information, eliminating cheating devices, and troubleshooting the causes of application performance crashes.

2. How do we collect and use your personal information and other information?

[Personal Information] Personal information refers to various information recorded electronically or otherwise that can, alone or in combination with other information, identify the identity of a specific natural person or reflect the activities of a specific natural person.

We will only collect and use your personal and other information for the following lawful purposes:

(I) Circumstances in which you authorize us to collect and use your personal information and other information

Our products and/or services include some specific business functions and additional functions. We may collect, store and use the following information about you to achieve these functions. If you do not provide relevant information, you may not be able to enjoy the products and/or services we provide.

Therefore, in order to provide products and services, you agree that we collect the following information:

1. Information that may be collected during your use of products or services.

We may collect information about your use of products and/or services (including how you use them), including:

1) 【Device Information】 In order to provide this product and/or service, we may collect device attribute information (such as your hardware model, operating system version, device configuration, network device hardware address MAC, etc.). We may associate the information collected from your various devices so that we can provide you with consistent services on these devices. We may associate your device information with your Top Comic account to maintain consistency in subsequent services.
2) 【Feedback Information】When you send us feedback through the feedback portal in the software, our system will store the feedback information you sent so that our customer service staff can review and respond.

We will encrypt the above-mentioned data information to ensure the security of the information.

(II) You are fully aware that we do not need to obtain your authorization or consent to collect and use personal information and other information in the following circumstances:

1. Related to national security and national defense security;
2. Related to public safety, public health, and major public interests;
3. Related to criminal investigation, prosecution, trial and execution of judgments, etc.
4. For the purpose of protecting the personal information and other information subjects or other individuals’ life, property and other major legal rights and interests, but it is difficult to obtain the consent of the individual;
5. The personal information and other information collected is disclosed to the public by the subject of the personal information and other information on his/her own accord;
6. Your personal information and other information collected from legally disclosed information, such as legal news reports, government information disclosure and other channels;
7. Necessary for signing a contract according to your requirements;
8. Necessary for maintaining the safe and stable operation of the products and/or services provided, such as discovering and handling product and/or service failures;
9. Necessary for legitimate news reporting (if applicable, but only for the purpose of achieving public interest);
10. When academic research institutions conduct statistical or academic research based on public interests (if applicable, but only for the purpose of achieving public interests) and provide the results of academic research or descriptions to the outside world, they shall de-identify the personal information and other information contained in the results;
11. Other circumstances stipulated by laws and regulations.

(III) Rules for the use of your personal information and other information

1. We will use the collected personal information and other information legally in accordance with the law and the provisions of this privacy policy and to realize the functions of our products and/or services.

2. After collecting your personal information and other information, we will use technical means to de-identify the data in accordance with legal provisions. De-identified information will not be able to identify the user subject. Please understand and agree that in this case we have the right to use the de-identified information; and without disclosing your personal information and other information, we have the right to analyze the user database and make commercial use of it.

3. 【Authorization of Use】Please note that all personal information and other information you provide when using our products and/or services will continue to be authorized for us to use during your use of our products and/or services, unless you delete it or refuse us to collect it through system settings.

4. We will collect statistics on the use of our products and/or services, and may share these statistics with the public or third parties (including but not limited to communication service providers that send emails or content notifications on our behalf, map service providers that provide us with location data, and financial service providers, etc.) to show the overall usage trends of our products and/or services, or to maintain and improve our services, but these statistics do not contain any of your personally identifiable information.

5. We will only share your personal information and other information for legitimate purposes. At the same time, we will desensitize your information by replacing content and anonymous processing to protect the security of your personal information and other information.

III. Circumstances in which your personal information may be lawfully shared, transferred, or publicly disclosed

(I) Sharing

1. We will not share your personal information with any company, organization or individual other than Top Comic, except in the following circumstances:

(1) Obtain your prior consent or authorization;
(2) Providing information as required by applicable laws and regulations, legal procedures, or mandatory administrative or judicial requirements;
(3) To the extent permitted by laws and regulations, it is necessary to provide information in order to protect the interests, property or safety of Top Comic, its affiliates or partners, you or other Top Comic users or the general public from damage;
(4) Only by sharing your information can we provide you with the services you need;
(5) To handle disputes or controversies between you and others upon your request;
(6) Comply with the relevant agreements signed with you (including online electronic agreements and corresponding platform rules) or other legal documents;
(7) Use for academic research (if applicable, but only for the purpose of achieving public interest);
(8) Use based on social public interests in accordance with laws and regulations.

2. We may share your personal information with our affiliates. However, we will only share necessary personal information and it will be subject to the purposes stated in this Privacy Policy. If our affiliates want to change the purpose of processing personal information, they will ask for your authorization and consent again. Our affiliates include our advertising, licensors, suppliers and other partners.

(II) Transfer

We will not transfer your personal information to any company, organization or individual, except in the following circumstances:

1. Obtain your consent or authorization in advance;
2. Provide as required by applicable laws and regulations, legal procedures, mandatory administrative or judicial requirements;
3. Comply with the relevant agreements signed with you (including online electronic agreements and corresponding platform rules) or other legal documents;
4. In the event of a merger, acquisition, asset transfer or similar transaction, if personal information is transferred, we will require the new company or organization that holds your personal information to continue to be bound by this Privacy Policy. Otherwise, we will require the company or organization to re-solicit your authorization and consent.

(III) Public Disclosure

We will only disclose your personal information publicly under the following circumstances and only after taking security measures that meet industry standards:

1. Disclose the personal information you specify in accordance with your needs and in the disclosure method you explicitly agree to;
2. In the event that your personal information must be provided in accordance with the requirements of laws and regulations, mandatory administrative law enforcement or judicial requirements, we may publicly disclose your personal information based on the type of personal information and disclosure method required. Subject to compliance with laws and regulations, when we receive a request to disclose the above information, we will require the production of corresponding legal documents, such as a subpoena or investigation letter. We firmly believe that the information we are required to provide should be as transparent as possible within the scope permitted by law. We carefully review all requests to ensure that they have a legal basis and are limited to data that law enforcement agencies have the legal right to obtain for specific investigation purposes. Subject to the permission of laws and regulations, the documents we disclose are protected by encryption keys.

(IV) Statement on Third-Party Liability

【Third-party services】Please note that your transaction counterparty, the third-party website operator you visit, and the third party connected through us (such as the third party providing services in the Top Comic APP) may have their own privacy protection policies; when you view web pages created by third parties or use applications developed by third parties, these third parties may place their own cookies or pixel tags, which are not under our control, and their use is not subject to this policy. We will make commercially reasonable efforts to require these entities to take protective measures for your personal information, but we cannot guarantee that these entities will take protective measures in accordance with our requirements. Please contact them directly to obtain details about their privacy policies. If you find that there are risks in these web pages created by third parties or applications developed by third parties, it is recommended that you terminate the relevant operations to protect your legal rights and interests. Top Comic recommends that you carefully review the privacy statements of such third-party websites or service providers to understand how they handle your personal information so that you can make prudent decisions.

4. User information collection instructions for third-party SDKs

V. How do we safely protect and store your personal information?

(I) Storage of Information

Personal information we collect and generate in the United States is stored in the United States.

Currently, Top Comic does not provide personal information outside the United States. If personal information is transferred or stored across borders in the future, we will inform you of the purpose, recipient, security measures and security risks of the information transfer and obtain your consent separately.

(II) Our technologies and measures to protect your personal information

We attach great importance to the security of personal information and take all reasonable and feasible measures to protect your personal information:

1. [Data Security Technical Measures] We promise that we will ensure that information security protection reaches a reasonable level of security. To protect your information security, we are committed to using various security technologies and supporting management systems to prevent your information from being leaked, damaged or lost, including establishing reasonable system specifications and security technologies to prevent your personal information from being accessed, used or modified without authorization, and to avoid data damage or loss.

Top Comic's network service uses encryption technologies such as the Transport Layer Security Protocol and provides security services through methods such as https to ensure the security of data during transmission.

Top Comic uses a variety of encryption technologies to encrypt and store user personal information, and isolates the storage media or information systems containing user personal information through logical or physical isolation to ensure security.

When using personal information, such as displaying personal information and calculating the association of personal information, we will use a variety of data desensitization technologies to desensitize sensitive fields and enhance the security of personal information during use.

2. [Other security measures taken by Top Comic to protect personal information]Top Comic regulates the security of personal information in internal storage, use, sharing, and other aspects by establishing an information classification and grading system, a user information security management system, and secure development specifications.

Top Comic implements comprehensive security control over data through confidentiality agreements with information contacts, monitoring and auditing mechanisms.

Top Comic monitors the behavior of its staff in handling your information, continuously trains its staff on relevant laws and regulations, privacy and security guidelines, and strengthens their awareness of security. It also organizes all staff to take security exams, holds security and privacy protection training courses, and strengthens employees' awareness of the importance of protecting personal information.

3. Please understand that due to technical limitations and various possible malicious means, problems may arise due to factors beyond our control. After an unfortunate personal information security incident occurs, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions for you to prevent and reduce risks on your own, and remedial measures for you. We will promptly inform you of the relevant circumstances of the incident by email, letter, telephone or content notification. When it is difficult to inform the subject of personal information one by one, we will take reasonable and effective measures to issue an announcement. At the same time, we will also proactively report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

VI. Protection of Minors’ Information

1. Top Comic attaches great importance to the protection of minors' personal information. If you are a minor under the age of 18, please ask your guardian to read this privacy policy carefully before using our products and/or services, and please use our products and/or services or provide us with information only with the consent of your guardian.

2. If your guardian disagrees with your use of our services or provision of information to us in accordance with this policy, please immediately stop using our services and contact us in a timely manner.

3. When we receive your written notice and know or we know on our own that Top Comic has collected personal information of minors without the prior consent of their guardians, Top Comic will immediately stop collecting and using the relevant information.

4. Top Comic will protect the confidentiality and security of minors' personal information in accordance with relevant national laws and regulations.

VII. Your Rights

We attach great importance to your management of personal information, and do our best to protect your rights to access, modify (update or correct), delete, withdraw authorization and cancel your account, so that you have sufficient ability to protect your privacy and security, and your opinions will be processed in a timely manner.

(I) Manage and withdraw your information

You can withdraw your consent by turning off the function, changing the application permissions in the device settings, changing the scope of your authorization for us to continue to collect personal information, or withdrawing your authorization. Please understand that specific business functions and services will require your information to be completed. When you withdraw your consent or authorization, we will no longer be able to provide you with the functions and services corresponding to the withdrawal of consent or authorization, and will no longer process your corresponding personal information. However, your decision to withdraw consent or authorization will not affect the previous processing of personal information based on your authorization.

(II) Visit Privacy Policy

You can view the full content of this privacy policy in the "Privacy Policy" in the client.
Please understand that the related services described in this Privacy Policy may vary depending on the phone model, system version, software application version, and mobile client factors you use. The final products and services are subject to the software and related services you use.

(III) Notify you of your rights when we stop operating

If we cease operations, we will promptly stop collecting your personal information, notify you of the cessation of operations by individual delivery or announcement, and delete or anonymize your personal information held.

(IV) Complaints and Reports

You can file a complaint or report in accordance with our publicized system. If you believe that your personal information rights may be infringed, or if you find clues of infringement of personal information rights, you can contact us in the "Customer Service Center" and enter the feedback interface. We will respond to your complaint and report within 15 working days after verification.

VIII. Notice and Revision

1. In order to provide you with better services and as Top Comic's business develops, this privacy policy will be updated from time to time. However, without your explicit consent, we will not reduce your rights under this privacy policy. We will issue updated versions on Top Comic's mobile terminal and remind you of updates to relevant content through website announcements or other appropriate means before they take effect. Please also visit Top Comic to keep up to date with the latest privacy policy.

2. If there are any major changes, we will inform you in a more prompt way, including but not limited to sending emails, letters, phone calls, software notifications, etc. Major changes referred to in this privacy policy include but are not limited to:

(1) Our service model undergoes significant changes;
(2) Changes in the main objects of public disclosure of personal information.

3. [Amendments to the Privacy Policy] Any amendments we may make to this Privacy Policy will constitute part of this Privacy Policy and will have retroactive effect. If you continue to use our products and/or services, you agree to be bound by the revised Privacy Policy.

IX. Applicable Law and Dispute Resolution

1. 【Applicable Law】The execution, interpretation and dispute resolution of this Privacy Policy shall be subject to the laws of the United States, without regard to any conflict of laws.

2. 【Dispute Resolution】 If you and Top Comic have any dispute regarding the content of this Privacy Policy or its implementation, the two parties shall resolve it through friendly negotiation. If the two parties are unable to resolve the dispute through negotiation, the two parties agree to submit the dispute to a court with jurisdiction over the location of the Company for litigation.

X. How to contact us

1. If you have any questions, comments or suggestions about this privacy policy or your personal information, please contact us by calling our customer service number or providing online feedback.

2. We have set up a dedicated department for personal information protection (or a personal information protection specialist). You can contact us by sending an email.

Note: This Privacy Policy was revised and took effect on August 6, 2024.

Contact email: [email protected]
Company Name: SH TRELLEBORG STUDIO LOHI , LLC
Office Address: 7601 E Technology Way Ste 600, Denver, CO, 80237, US

August 6, 2024